Key legal question
Whether depreciation on the property A. street was deductible as business property for direct federal tax 2006.
Extracted holding
No. The property was not directly used in the real estate trading business and no ordinary depreciation was permissible.
Extracted reasoning
A leased property does not become business operating assets merely because tenants are controlled through the taxpayer’s holding structure. Ordinary depreciation requires actual value wear from use or time, which was not shown.