1995),[1] was a decision by the Second Circuit of the United States Court of Appeals relating to the deductibility of expensive items or tools that may increase in value as a collectible but decrease in value if used in the course of a business or trade.

Whether petitioners are entitled to deduct depreciation claimed under the accelerated cost recovery system for the year in issue.

Prior to the passage of the Economic Recovery Tax Act of 1981 (ERTA), the depreciation of personal property was solely determined by § 167 of the Internal Revenue Code of 1954.

Calculating depreciation under this part of the code required the taxpayer to determine the "useful life" of property which was difficult and often led to disagreements.

Even though the fair market value of bows increased, the court stated that for it to look into determining whether an asset has a "separate, non business" value for depreciation purposes would be contrary to Congress's intent to simplify this concept.

They state that the Internal Revenue Code, in accordance with congressional intent, meant for these "works of art" to be non-depreciable property since instruments and other collectibles have an indeterminable useful life.