James E. Copley and Cynthia R. Copley - Page 17

                                         17                                           
                      Year              Amount of Depreciation                        
          1985                      $2,906                                            
          1986                      13,374                                            
          1987                      12,225                                            
          1988                       6,364                                            
          1989                         451                                            
          Total                   35,320                                              
          Such figures would seem to indicate that petitioners did, in                
          fact, rent out the California property beginning in 1985.                   
          Petitioner's testimony that he resided at that address from 1985            
          through 1988 while working at General Dynamics was uncorroborated           
          and questionable.  Under such circumstances, petitioners have               
          failed to establish that the property was ever used as their                
          principal residence, or that even if it were, that such use was             
          not abandoned long before the property was sold.  See Stolk v.              
          Commissioner, 40 T.C. 345 (1963), affd. per curiam 326 F.2d 760             
          (2d Cir. 1964).  We are unable, moreover, to determine with any             
          degree of certainty the location of petitioners' new residence              
          after the sale of the California property in 1989.                          
               On their 1989 Federal income tax return, petitioners listed            
          their address as "P.O. Box 4353, Star City, West Virginia, 26504"           
          (the Star City address), and a Form 1099-INT attached to their              
          return listed petitioners' residence as "500-6 Village Park                 
          Drive, Morgantown, West Virginia, 26505" (the Morgantown                    
          address).  On their amended 1989 return, petitioners listed their           
          residence in 1989 as the Charleston property.  On their 1990                
          Federal income tax return, petitioners listed their home address            




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