Eli T. Sleiman, Jr. and Janie L. Sleiman, et al. - Page 30

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          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.                          
















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