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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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