Kelvin & Arlene Jackson - Page 18




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          However, respondent allowed petitioners only a $1,520 CGS                   
          deduction “Since all of the books purchased were not sold during            
          taxable year 2000”.                                                         
               Petitioners claim that “Some of this inventory was utilized            
          for garnering bookstores as distributors of products, and for               
          advertising/publicity packages to newspapers, consumer health               
          information organizations, television stations, and radio                   
          stations for printed reviews.”  Petitioners presented an invoice            
          from Bacon’s Mailing Service that indicated that they had                   
          purchased 511 press kits that would contain one paperback book              
          each when mailed or shipped.  Petitioners did not provide any               
          evidence that they actually mailed or shipped the press kits,               
          other than UPS receipts that indicated books with a declared                
          value of $550 had been shipped.  Petitioners have not shown that            
          the $550 declared value was not included in the $1,520 CGS                  
          allowed by respondent, nor have they shown that they are entitled           
          to CGS in excess of that allowed by respondent.  Accordingly, the           
          Court sustains respondent on the CGS issue for taxable year 2000.           
               E. Depreciable Assets                                                  
               A taxpayer may elect to deduct as a current expense the cost           
          of any section 179 property, with certain dollar limitations,               
          that is acquired for purchase in the active conduct of a trade or           
          business and placed in service during the taxable year.                     
          Sec. 179(a), (b), (d)(1); see sec. 1.179-4(a), Income Tax Regs.             







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