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Case: Deficiency Determinations for Disallowed Farm Equipment Expense Amounts Upheld, With Penalties for Portions Relating to Duplicate Claims (T.C. Memo) (IRC §179)

Dec. 5, 2022, 5:00 AM

A farming husband and wife are liable for deficiencies in three tax years at issue as a result of their claiming equipment expense and depreciation deductions beyond amounts to which IRS determined they were entitled, the U.S. Tax Court held in a memorandum opinion. As to accuracy-related penalties, the court found Taxpayers liable for portions attributable to certain deductions that totaled the same for each year — that they knew or should have known such deductions were duplicates and not proper — and otherwise found them to have acted with reasonable cause and in good faith. [Hoakison v. Commissioner ...