DICKERSON v. COMMISSIONER

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

The primary issue for decision is whether a practicing attorney is entitled to a depreciation deduction for an enclosed swimming pool at her residence.

Petitioner filed her 1985 return late on October 20, 1986.

Respondent determined a deficiency in petitioner's Federal income tax for 1985 in the amount of $3,510 and additions to tax as follows:

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