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Hendersons' (Ps) son, Bradley, suffers from spina bifida and is confined to a wheelchair. Ps purchased a van for the sole purpose of transporting Bradley. The purchase price was approximately $26,000. Bradley's physician believed that, due to Bradley's increasing weight and size and his prolonged medical condition, a wheelchair lift was necessary. Ps modified the van specifically for Bradley's medical needs by installing an automatic wheelchair lift and raising the roof of the van. Such modifications cost an additional $4,406. On a weekly basis, transported Bradley to and from hospitals and doctors' appointments in Spokane and Seattle, Washington. The specially modified van was the only means of transportation for Bradley. Ps used two other vehicles for their own transportation. The van was also used to transport Bradley to and from school every day. Ps also used the van whenever they needed to take Bradley on trips with them. On the recommendation of their certified public accountant, Ps deducted the cost of the van and the conversions at a rate of $5,500 per year for 1991, 1992, 1993, 1994, and 1995. IRS (P) audited the1994 and 1995 tax returns and denied Ps' depreciation deduction for both years.

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