John Robert Maguire - Page 13

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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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