Simon v. Commissioner

Professional violinists Richard and Fiona Simon (plaintiffs) bought two relatively unused nineteenth-century Tourte violin bows in 1985, and through years of professional use the bows' sound-producing quality noticeably deteriorated even as their fair market antique value rose; the Simons deducted depreciation on their 1989 tax return under ACRS, and the Commissioner (defendant) issued a deficiency notice, arguing the appreciating value precluded depreciation.