Maintenance, Painting & Construction, Inc. - Page 3

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          We find the stipulated facts accordingly.  Petitioner is a C                
          corporation with a fiscal year ending on May 31.  It specializes            
          in the repair and painting of buildings in the State of                     
          Tennessee.  Its mailing address was in Brighton, Tennessee, when            
          its petition was filed.                                                     
               In 1992, petitioner was awarded a contract (contract) to               
          repair and paint 1,500 service stations in California, Arizona,             
          Nevada, Oregon, Washington, and Alaska.  Petitioner began working           
          on the contract in 1992 and purchased in and around California              
          most of the trucks, automobiles, and other equipment                        
          (collectively, equipment) necessary to complete its work under              
          the contract.  The equipment was generally used property                    
          purchased at auction.                                                       
               In 1994, petitioner began storing on a lot (lot) in                    
          California some of the equipment that had become inoperable.  The           
          record does not indicate that petitioner documented the assets              
          which it placed on the lot.  On May 31, 1995, petitioner sold               
          some of the equipment located on the lot for $30,000.  Petitioner           
          reported on its Federal income tax return for its 1995 taxable              
          year that it had paid $360,728 for the equipment sold in that               
          transaction, and it claimed a $199,408 loss with respect to the             
          sale.  Petitioner reported on the return that the assets sold in            
          the transaction were “VARIOUS ASSETS–-CA” and did not otherwise             
          identify those assets.                                                      






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