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to the Wallingford Tax Office or the $248 payment, and we sustain
respondent's disallowance of these items.
Miscellaneous items
Respondent disallowed the following deductions that
petitioner characterized as supplies: $12 for books; $3,649 for
rugs; $883 for a television; $107 for furniture; $45 for sheets;
$90 for pillows; $658 for lamps; and $101 for linens. Petitioner
testified that he rented the Harwichport property furnished in
1991, but we do not consider this general testimony sufficient to
conclude that the items outlined above related to the production
of income from the Harwichport property in 1990. We sustain
respondent's disallowance of these items in 1990.
Depreciation of Capital Improvements
Respondent disallowed depreciation deductions related to
$16,064 of capital improvements allegedly made in 1989.
Petitioner argues that in 1989 he added $16,064 of capital
improvements to the Harwichport property, and he began
depreciating those improvements in 1990. The taxpayer must
establish the property's depreciable basis by showing the cost of
the property, its useful life, and the previously allowable
depreciation. E.g., Delsanter v. Commissioner, 28 T.C. 845, 863
(1957), affd. in part, revd. in part and remanded per curiam 267
F.2d 39 (6th Cir. 1959). Petitioner's father testified that the
cost of "some" of the 1989 improvements to the property was
"carried over" to 1990 and added to the depreciable basis of the
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