Sammy Jones is employed full-time as an accountant for a large bank. In his spare time, he operates a secondary business as a self-employed wedding photographer. On January 3rd of the current year, Sammy purchased new video recording equipment for $22,700. Throughout this year, he used this equipment for personal enjoyment (filming his family members on holidays and during vacations). He also used the equipment for business purposes when a client wanted video coverage of a wedding. Sammy did not purchase any other property for business use during the year. Sammy kept a careful written record of the time that he used the video recording equipment for either personal or business reasons during the year. This record substantiates that he used the equipment 59 percent of the time for personal reasons and 41 percent of the time for business reasons. Can Sammy elect to expense any of the cost of the video recording equipment under Section 179?

Required:

Write a tax memorandum supporting your position on Sammys situation.