
    Appeal of ANTONIO ALBIANI.
    Docket No. 663.
    No evidence having been introduced in support of the taxpayer’s position, the determination of the Commissioner is approved.
    Submitted January 26, 1925;
    decided February 10, 1925.
    
      James V. Giblin, C. P. A., for the taxpayer.
    
      W. Frank Gibbs, Esq. (Nelson T. Hartson, Solicitor of Internal Revenue) for the Commissioner.
    Before James, Sternhagen, and Trussell.
    This appeal involves income tax for the years 1919, 1920, and 1921, The Commissioner has found additional tax due for the year 1919 of $25.65, for the year 1920 of $221.60, and an overassessment for the year 1921 of $33.29, a net deficiency of $213.96. The taxpayer alleges that he is entitled for the year 1919 to additional depreciation upon certain property in the sum of $615.
    
      FINDINGS OF FACT.
    The taxpayer throughout the periods in question was the owner of two separate rental properties located at Cambridge and Chelsea, Mass. For each of the years 1920 and 1921 the examining revenue agent fixed a total sum of $615 as a reasonable allowance for exhaustion, wear, and tear of property on account of these properties. This allowance was not made for the year 1919.
   DECISION.

The determination of the Commissioner of a deficiency for the year 1919 in the sum of $25.65, for the year 1920 in the sum of $221.60, and an overassessment for the year 1921 in the sum of $33.29 (a net deficiency for the three years in the sum of $213.96), is approved.  