Hans H. and Cheryl E. Hammann - Page 13

                                       - 13 -                                         
                    Year           Amount of Depreciation Deducted                    
                    1983                     $3,277                                   
                    1984                     3,072                                    
                    1985                     2,880                                    

               Respondent determined that the appropriate conversion rate             
          from German deutschemarks to dollars at the time of the purchase            
          was 2.13 deutschemarks to the dollar.  She further determined               
          that the useful life of the condominium was 25 years rather than            
          20, and that current depreciation deductions should be computed             
          by using the straight-line method of depreciation.  As a result,            
          respondent reduced the depreciation deduction for each year as              
          follows:                                                                    
                    Year                     Amount                                   
                    1983                     $1,743                                   
                    1984                     1,538                                    
                    1985                     1,346                                    
          The average conversion rate from deutschemarks to dollars during            
          1981 was 2.25 deutschemarks to the dollar.6                                 
          State Income Tax Refunds                                                    
               Petitioners received refunds of state income taxes as                  
          follows:                                                                    
                    Year                Amount of Refund                              
                    1984                    $1,538                                   
                    1985                    1,346                                    
          Petitioners did not include the refunds in income.  Respondent              
          increased petitioners' income for each year by the amount of the            

          6Statistical Abstract of the United States 887 (104th ed.                   
          1984).  See Fed. R. Evid. 201.                                              





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