Liddle v. Commissioner
United States Tax Court
103 T.C. 285 (1994)
Brian Liddle (plaintiff), a professional musician, used a 200-year-old antique instrument for all his professional work, and the instrument had suffered wear and tear from decades of successful use by earlier musicians. Liddle claimed the instrument qualified as "recovery property" eligible for the accelerated cost-recovery system (ACRS) deduction under § 168(a) of the tax code; the commissioner (defendant) disallowed the deduction, and Liddle petitioned the tax court for redetermination.
Whether, under the accelerated cost-recovery system, a work of art regularly used for trade or business is eligible for a federal tax deduction for its depreciation, even though the duration of the work's useful economic life is indeterminable.