Eli T. Sleiman, Jr. and Janie L. Sleiman, et al. - Page 26

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          real properties.  The remaining amounts were lent and borrowed              
          for construction and renovation activities.  Finally, our                   
          interpretation of the third sentence of section 164(a) is                   
          consistent with our holding with respect to ME's loan commitment            
          fee and attorney's fees, supra, in that costs incurred in                   
          connection with obtaining a loan should be amortized over the               
          definite term of the loan in lieu of being currently deductible             
          or depreciable over the useful life of the property acquired with           
          the loan proceeds.  Cf. Anover Realty Corp. v. Commissioner, 33             
          T.C. 671, 674-675 (1960).                                                   
               We hold that REE and ME are required to amortize the taxes             
          in issue over the definite terms of their construction loans.8              
          Rental Income                                                               
               The fifth issue for decision is whether REE and TNE are                
          required to report tenant improvements as rental income.                    
               Under the lease agreements with Blockbuster, REE and TNE               
          were responsible for purchasing and installing Blockbuster's                
          standard carpeting.  Contrary to the lease agreements, however,             
          Blockbuster purchased and installed the carpeting at both the               
          Dunn and Roosevelt properties at costs of $11,020.43 and                    
          $10,023.31, respectively.                                                   


          8         For reasons akin to our findings with respect to the              
          amortization period for ME's construction loan commitment fee and           
          related attorney's fees, we find that REE's construction and                
          permanent loans constitute separate loans for purposes of                   
          amortization.                                                               




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