George Tsakopoulos and Drousoula Tsakopoulos - Page 10




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          the zoning restrictions were depressing the value of Calvine                
          120/140.  Petitioner filed a letter with the County outlining his           
          plans to subdivide Calvine 120/140 into 947 single-family lots              
          and other sites.                                                            
               On his 1995 tax return, petitioner deducted real estate                
          property taxes of $26,985 for Calvine 120, and $35,180 for                  
          Calvine 140.  Respondent disallowed the deduction and determined            
          that the amounts were capital expenditures.                                 
          Payment to Consolidated Electrical Distributors                             
               On December 29, 1995, petitioner paid Consolidated                     
          Electrical Distributors $7,472 from his Greenhaven Plaza bank               
          account.  On his 1995 tax return, petitioner deducted this amount           
          as a repairs expense with respect to his Greenhaven property.               
          Respondent disallowed this amount because petitioner did not                
          establish the amount as an ordinary and necessary business                  
          expense.                                                                    
                                       OPINION                                        
          I.   Evidentiary Issue                                                      
               As a preliminary matter, petitioner objects to the admission           
          of the preliminary change of ownership report (the report) as               
          hearsay.  At trial, the Court admitted the exhibit under                    
          advisement, reserving ruling on the objection until parties                 
          briefed the issue.                                                          








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