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ARENS v. COMMISSIONER

Docket No. 20195-88.

59 T.C.M. 589 (1990)

T.C. Memo. 1990-241

Theodore G. Arens and Pamela J. Arens v. Commissioner.

United States Tax Court.

Filed May 17, 1990.

Attorney(s) appearing for the Case

Nestor M. Nicholas, One Boston Place, Boston Mass., and David Kavanaugh, for the petitioners. Ronald F. Hood, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $46,726 in petitioners' Federal income tax for the taxable year 1985.

The issue for decision is whether petitioner-husband, Theodore G. Arens, is entitled to avoid the short taxable year limitation of section 168(f)(5)1 and the proposed regulations thereunder with respect to a claimed accelerated cost recovery (ACRS) deduction on equipment because...

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