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the outside of the barn with a red oil-based paint. The
structure of the barn was not altered. The work done to the barn
increased its hay storage capacity2 and enhanced the appearance
of the property. The granary roof also was fixed and the sides
were treated and repainted in the same manner as the Rhodes barn.
Petitioner spent $28,100 in 1991 to make repairs to, make
improvements on, and demolish and remove buildings on the Rhodes
property. She deducted the following expenses as repairs on her
1991 tax return:
Repair of Rhodes barn roof $6,800
Preparation and painting of sides of Rhodes barn 7,200
Repair and removal of debris from interior of
Rhodes barn 1,500
Repair of Rhodes granary roof 2,700
Preparation and painting of sides of Rhodes
granary 3,600
Total 21,800
The $6,300 cost of demolishing a house and a storage building and
removing the debris was not deducted by petitioner. Petitioner
also deducted $250 in 1991 for the replacement of a water heater
in a small house on the Rhodes property. At trial, petitioner
conceded that the $1,500 cost of replacing two of the three
structural support rods was a capital improvement.
The Whitefeather Property
Petitioner purchased the Whitefeather property from her
parents in 1993 for $25,000. The property consists of 40 acres
2 Repairing the leaking roof allowed more hay to be stored.
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