Brian P. Liddle Brenda H. Liddle v. Commissioner of the Internal Revenue Service

OPINION OF THE COURT

McKEE, Circuit Judge:

In this appeal from a decision of the United States Tax Court we are asked to decide if a valuable bass viol can be depreciated under the Accelerated Cost Recovery System when used as a tool of trade by a professional musician even though the instrument actually increased in value while the musician owned it. We determine that, under the facts before us, the taxpayer properly depreciated the instrument and therefore affirm the decision of the Tax Court.

I

Brian Liddle, the taxpayer here, is a very accomplished professional musician. Since completing his…