Legal Opinion

Simon v. Comm'r

United States Tax Court

Decided August 22, 1994No. Docket No. 4817-92Published

Ps claimed depreciation deductions under the accelerated cost recovery system (ACRS), sec. 168, I.R.C., on two 19th-century violin bows that Ps actively, regularly, and routinely used in their trade or business as full-time professional violinists. R disallowed these deductions. R argues that the bows are depreciable under ACRS only if Ps prove the useful life of each bow under the law that applied before ACRS.

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Ps claimed depreciation deductions under the accelerated cost recovery system (ACRS), sec. 168, I.R.C., on two 19th-century violin bows that Ps actively, regularly, and routinely used in their trade or business as full-time professional violinists. R disallowed these deductions. R argues that the bows are depreciable under ACRS only if Ps prove the useful life of each bow under the law that applied before ACRS. R also argues that the useful lives of the bows are indeterminable because the bows are treasured works of art that appreciate in value and for which it is impossible to determine…

1Opinion of the Court

Richard L. Simon and Fiona Simon, Petitioners v. Commissioner of Internal Revenue, Respondent

Simon v. Comm'r

Docket No. 4817-92

United States Tax Court

103 T.C. 247; 1994 U.S. Tax Ct. LEXIS 60; 103 T.C. No. 15;

August 22, 1994, Filed

Decision will be entered under Rule 155.

Ps claimed depreciation deductions under the accelerated cost recovery system (ACRS), sec. 168, I.R.C., on two 19th-century violin bows that Ps actively, regularly, and routinely used in their trade or business as full-time professional violinists. R disallowed these deductions. R argues that the bows are depreciable under ACRS…

Also in this document: Dissent · Chiechi; Concurrence · Ruwe; Concurrence · Beghe; Dissent · Hamblen; Dissent · Gerber; Dissent · Halpern.

2Cases cited35 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. United States v. LudeySupreme Court of the United States · 1927
  4. Lindheimer v. Illinois Bell Telephone Co.Supreme Court of the United States · 1934
  5. American Automobile Assn. v. United StatesSupreme Court of the United States · 1961

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