Wy'East Color, Inc. An Oregon Corporation - Page 32

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          Freedson v. Commissioner, 565 F.2d 954 (5th Cir. 1978), affg. 65            
          T.C. 333 (1975) and 67 T.C. 931 (1977); McCoy v. Commissioner, 76           
          T.C. 1027 (1981), affd. 696 F.2d 1234 (9th Cir. 1983).  Even if             
          petitioner's documents had been admitted, we would give them very           
          little weight because they apply to periods much later than the             
          years in issue.                                                             
               Petitioner contends that Pietka did not consider that                  
          Mr. Cummings made repairs.  Petitioner points out that                      
          Mr. Cummings paid about $70,000 to repair the roof and dry rot              
          in 1994.  We make no findings about who paid for repairs during             
          the years in issue.  We would give little weight to evidence of             
          who paid for repairs in 1994 because it occurred so long after              
          the years in issue.                                                         
               Petitioner contends that Pietka considered an incorrect                
          amount of square footage for the 4200 S.W. Corbett St. property.            
          The parties agree that the 4200 S.W. Corbett St. property                   
          included a 33,631 square-foot production facility.  They disagree           
          about the size of the other areas.  Petitioner contends that the            
          shop has 4,050 (rather than 3,969) square feet and that the annex           
          or residence has 2,408 (rather than 2,316) square feet.  These              
          differences are de minimis.                                                 
               Petitioner contends that Pietka did not consider all of the            
          property that was subject to the lease.  Petitioner argues that             
          it leased property other than the 4200 S.W. Corbett St. property,           





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