- 30 - burden of clearly showing the right to the claimed deduction is on petitioners. Id. at 84. This Court has repeatedly held that costs incurred for carpeting generally constitute capital expenditures. LaPoint v. Commissioner, supra; Otis v. Commissioner, 73 T.C. 671, 674 (1980); Matlock v. Commissioner, T.C. Memo. 1992-324. Petitioners appear to have abandoned the position claimed on REE's return, since they did not address the deductibility of the carpeting costs in their trial memorandum or their briefs. We find that they have failed to prove that REE is entitled to its claimed repairs expense deduction. We hold that REE must capitalize the carpeting costs incurred by Blockbuster as part of its basis in the Dunn property. Likewise, we hold that TNE must increase its basis in the Roosevelt property by the carpeting costs incurred by Blockbuster on its behalf. To reflect the foregoing, Decisions will be entered under Rule 155.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011