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Liddle v. Commissioner

United States Tax Court
103 T.C. 285 (1994)


Facts

Brian Liddle (plaintiff), a professional musician, used an antique instrument for all of his work. The instrument had been used successfully by earlier musicians for at least 200 years, although the use had exposed the instrument to wear and tear. Liddle claimed that because he used the antique instrument professionally, it was “recovery property” under § 168 of the federal tax code and eligible for the accelerated cost-recovery system (ACRS) tax deduction under § 168(a). The commissioner of internal revenue (commissioner) (defendant) disallowed the ACRS deduction, and Liddle petitioned the tax court for a redetermination.

Rule of Law

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Issue

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Holding and Reasoning (Laro, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
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  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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Dissent (Halpern, J.)

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