Thank you for the response, but I don't think that actually answers my question. I think the more pertinent word is "allowed."

To compare it to a different tax issue, IRC 167 states, "There shall be allowed as a depreciation deduction...". When dealing with depreciation recapture, you have to recapture the amount allowed or allowable, which means you aren't required to deduct depreciation but you must recapture it even if you didn't deduct it.

Do you disagree?