Helen Sophie Schroeder - Page 6

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          and includes a large farmhouse, a small three-room house that                      
          petitioner used as an office, a chicken coop, a garage, a pump                     
          shed, and a barn (Whitefeather barn) to which a sheep shed and a                   
          cow stable were attached (collectively referred to as the                          
          Whitefeather buildings).  The Whitefeather barn was built about                    
          1932 or 1933 and was in usable condition.  Petitioner has used                     
          the barn to store hay and stable horses for the last 15 years.                     
          Petitioner could not remember the last time the Whitefeather barn                  
          had been sealed or painted.                                                        
                In 1991, petitioner resealed and painted the wood on the                     
          Whitefeather barn, installed new windows, fixed the doors and                      
          roof, divided a horse stall into two foaling stalls, and                           
          demolished the sheep shed and the cow stable attached to the                       
          barn.  Petitioner also had the chicken coop demolished.  The work                  
          on the roof of the barn included resilvering, caulking, replacing                  
          one or two of the approximately 120 tin sections of the roof, and                  
          reinstalling lightning rods.  Although the work did not increase                   
          the Whitefeather barn's storage capacity, it did enhance its                       
          appearance.                                                                        
                Petitioner deducted the following expenses as repairs to the                 
          Whitefeather property on her 1991 tax return:                                      
          Repair roof of Whitefeather barn                       $2,400                      
          Preparation and painting of Whitefeather barn           2,300                      
          Total                                             4,700                            
          Petitioner's invoice for the above described work was consistent                   
          with the description on her tax return.  It made no reference to                   




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