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improvements and repairs to the same specific asset, usually a
structure in a state of disrepair." Moss v. Commissioner, supra
at 839 (fn. ref. omitted).
In Kaonis v. Commissioner, T.C. Memo. 1978-184, affd.
without published opinion 639 F.2d 788 (9th Cir. 1981), we
separated capital expenditures from repairs and allowed the
taxpayer a deduction for the repairs to a rental house.
Specifically, we found that the taxpayer's expenses for painting
and cleaning restored the property to its previous condition and
thus were deductible. We declined to apply the rehabilitation
doctrine because "the property was tenantable and generally
suitable for its use in the trade or business." Id. Here,
likewise, the two barns and the granary were suitable for use in
petitioner's trade or business prior to the repairs; they had
been used by petitioner for over 10 years.
Respondent points out that the repairs to the Rhodes barn
increased its capacity to store hay. In Keller Street Dev. Co.
v. Commissioner, 37 T.C. 559 (1961), affd. in part and revd. in
part on other grounds 323 F.2d 166 (9th Cir. 1963), the taxpayer,
a brewery, made some capital improvements to its plant and
equipment. Most of the improvements were designed to increase
productive capacity so that the brewery could fill increasing
demand. The Commissioner argued that certain expenses deducted
by the taxpayer should have been capitalized because they were
"part of a general betterment program". Id. at 567. However, we
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