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LINSMAYER v. COMMISSIONER

Docket No. 15094-92.

70 T.C.M. 664 (1995)

T.C. Memo. 1995-437

Robert M. Linsmayer v. Commissioner.

United States Tax Court.

Filed September 12, 1995.

Attorney(s) appearing for the Case

Mark A. Pridgeon, Edina, Minn., for the petitioners. Jack Forsberg, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SCOTT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1985 in the amount of $15,973.20 and an addition to tax under section 6651(a)(1) of $1,700.80.

The issues for decision are: (1) Whether petitioners are entitled to deduct a pro rata portion of a full year's depreciation computed under the accelerated cost recovery system provided for in section 168

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