Hans H. and Cheryl E. Hammann - Page 12

                                       - 12 -                                         
          accordance with the provisions of that section.5  For the years             
          1984 and 1985, respondent disallowed all of the expenses claimed            
          for lack of substantiation.  Unlike 1983, respondent did not                
          allow any expenses pursuant to section 183 for the years 1984 and           
          1985.  Due to respondent's characterization of petitioners'                 
          charter boat service, all investment tax credits claimed relating           
          to that activity were disallowed.                                           
          Cheryl Hammann's Condominium                                                
               Prior to her marriage to Hans Hammann, Cheryl Hammann                  
          purchased a condominium in Augsberg, Germany.  She paid 102,000             
          German deutschemarks for the property.  Petitioners converted the           
          purchase price to dollars using a conversion rate of 1.56                   
          deutschemarks to the dollar, resulting in a cost basis of                   
          $65,545.  In computing the depreciation deduction for each year,            
          they allocated 20 percent of the cost to land and 80 percent of             
          the cost to the building.  They used the 125-percent declining-             
          balance method to compute their annual depreciation deduction               
          based upon a 20-year useful life.  The condominium was rented to            
          unidentified tenants during the years 1983, 1984, and 1985.                 
          After taking into account depreciation deductions claimed in                
          previous years the following depreciation deductions were claimed           
          on petitioners' returns with respect to this condominium:                   

          5Consistent with respondent's determination, the allowed                    
          expenses were taken into account in respondent's adjustment to              
          petitioners' itemized deductions.                                           





Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011