Maurice E. Hodgkins and Barbara J. Hodgkins - Page 18

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          the other, but never by both.  Petitioners failed to prove that             
          they lost their deposit.                                                    
          d.  Improvements                                                            
               Respondent disallowed $9,191 of improvements that                      
          petitioners had included in basis.  Respondent determined that              
          the improvements were either unsubstantiated or previously                  
          deducted as repairs.  Crow Canyon needed work when petitioners              
          purchased it.  They deducted $2,739 for repairs in 1986 and                 
          $5,500 in 1987.  Petitioners also included in basis an additional           
          $9,191 as improvements.  Petitioners' sole substantiation for               
          these repairs and improvements was a few receipts from 1986                 
          totaling $1,763.31.  Petitioners failed to distinguish these                
          items from those amounts already deducted as repairs.  We                   
          therefore deny petitioners' increase in basis for improvements.             
          e.  Interest Paid in Escrow                                                 
               Respondent also determined that the first mortgage interest            
          payment of $3,670 did not belong in the basis of Crow Canyon.               
          Petitioners concede that they deducted $612 of the interest                 
          payment in 1986 and are therefore not entitled to include that              
          amount in basis.  The lender also charged petitioners a $50 fee             











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