*3456 Exhaustion, wear and tear, and obsolescence of laundry machinery determined at a rate of 10 per cent.
The respondent determined a deficiency of $470.43 for 1921 by disallowing the petitioner's deduction for depreciation of laundry machinery at a rate of 10 per cent and applying instead a rate of 8 per cent.
FINDINGS OF FACT.
The petitioner is an Illinois corporation engaged in the business of operating a laundry in Chicago.
During the year 1921 it owned certain machinery such as a boiler, washers, extractors, ironers, starch cookers, and other apparatus which it used in the conduct of its business. The useful life of the individual items of this machinery varied in the main from eight to twelve years. A fair probable average useful life of all the machinery is ten years, and a reasonable allowance for exhaustion, wear and tear, including a reasonable allowance for obsolescence, is 10 per cent.
OPINION.
STERNHAGEN: The evidence consisted of a complete list of the property in question and the statements of three witnesses in the laundry business, *3457 two of whom knew the specific property and the third who knew the classes of property, all of whom testified as to the life of each item. From this evidence we find that a reasonable allowance for exhaustion, wear and tear of petitioner's laundry machinery, including a reasonable allowance for obsolescence, is 10 per cent.
Judgment will be entered on 15 days' notice, under Rule 50.