Sam H. Patton (2001)

116 T.C. No. 17

UNITED STATES TAX COURT SAM H. PATTON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16428-99. Filed April 13, 2001.

For 1995, P elected, under sec. 179, I.R.C., to expense a depreciable asset. R examined P's 1995 Federal income tax return and reclassified as depreciable three assets that P had originally classified as 'materials and supplies'. Following R's reclassification, P sought R's consent to expense the three reclassified assets under sec. 179, I.R.C. P was unable to revoke (modify or change) his election without R's consent. R refused to give P consent to rev...

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