The Tax Court held that the basis for depreciation of a nonbusiness property which the taxpayers transferred to a business partnership as part of their contribution was the fair market value of such property at the time of such transaction (40 T.C. 264). This conclusion finds support in and is consistent with *1009 the doctrine implied in Helvering v. Owens, 305 U.S. 468, 59 S.Ct. 260, 83 L.Ed. 292 (1939).

The judgment of the Tax Court in determining a deficiency is affirmed.