How have the courts dealt with the use of the useful lives of depreciable assets under Rule 155 of the Tax Court Rule 155?
MultiRegion, United States of America
The following excerpt is from Erhard v. C.I.R., 46 F.3d 1470 (9th Cir. 1995):
Finally, Erhard challenges the tax court's computations under Tax Court Rule 155. Computations under Rule 155 are reviewed for an abuse of discretion. Kelly v. Commissioner, 877 F.2d 756, 760 (9th Cir.1989). Erhard alleges that the tax court abused its discretion (1) by refusing to accept his computations as to the useful lives of the depreciable assets, and (2) by refusing to credit him for amounts that he withheld from his payments to ICF.
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