@Ghost-Tax  the taxpayer claimed no depreciation expense on the building for the entire time that he owned it?  Did the auditor in his computations allocate the amount of the property's purchase price to land/lot and to the building? 

Did the taxpayer operate his business at the building immediately after he acquired it, or was there a period of time between purchase and conducting the business at the building?  How many years did the taxpayer operate a business at the building?  Did the taxpayer move the business out of the building in order to sell the building?  When did the taxpayer cease operations at the building?   What portion of the building was used for business operations?  Was the entire building used for his business, or was only a portion of the building used for the business? 

To compute the correct amount of depreciation "allowed or allowable" a timeline and the percent of business use are required to determine the correct amount of depreciation the auditor is using for his computations.