Lobeck (1990, 1995) and Saito and Murasugi (1990) argue that the functional categories (C, T, D) permit the ellipsis of their complements only when their Spec positions are filled. I propose that this licensing condition on ellipsis is extended to the functional category v and claim that there are two types of VP-ellipsis: one is v P-deletion, which is licensed in the functional category TP and the other is VP-deletion, which is licensed in the functional category v P. I argue that the proposed analysis of VP-ellipsis is supported by considering inversion constructions, voice mismatch and VP-ellipsis in infinitival clauses.