- 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.
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