MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined Federal income tax deficiencies for petitioner's tax fiscal years ended in August 1996, August 1997, and August 1998, in the amounts of $147,277, $31,983, and $46,729, respectively. At trial, petitioner conceded that the modified accelerated cost recovery system (MACRS), alternative depreciation system rules, in accordance with section 168(g)(1), required petitioner to use a 10-year...
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