Question juridique clé
Whether the mixed-use property qualified as business assets so that depreciation was deductible for direct federal tax.
Solution extraite
Because the business use was only 7.6%, the property had to be allocated entirely to private assets; depreciation was therefore not deductible.
Motifs extraits
Under the preponderance method, a mixed-use asset is business property only if it serves the self-employed activity to more than 50%. The cantonal findings on use were binding and the taxpayers did not undermine the authority's figures; the claim that the spouse worked in the business did not change the asset classification.