Sharp v. United States

The Sharps (plaintiffs) used their jointly owned airplane roughly 74% for personal use and 26% for business, claimed depreciation deductions matching the business-use portion, and sold the plane for a total gain; they argued the entire sale should be treated as one property with a single basis (yielding an overall loss), while the government (defendant) allocated the cost, depreciation, and proceeds separately between the business and personal portions (yielding a taxable business gain).