Ronald P. Barranti and Stephanya M. Barranti - Page 12

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          and remanding in part T.C. Memo. 1956-178.  With these principles           
          in mind, we find that petitioner's estimates of the value of the            
          work performed by Murray are reasonable, except for two amounts.            
               Petitioner estimated that the cost of repairing and painting           
          the fence was $1,000.  We find this amount excessive.                       
          Petitioners submitted a written market analysis (the report) of             
          the fair market value of her property which was prepared by a               
          Century 21 real estate agent (the agent).  Petitioner testified             
          that the agent who performed this analysis came to the property             
          and inspected both the exterior and the interior of the house.              
          Furthermore, petitioner testified that she agreed with the                  
          evaluation of her property as presented in the report.  The                 
          report has a section titled "Condition Report" which provides a             
          check list of exterior items that have been inspected, and a                
          space for the agent to comment on any repairs that may be needed.           
          The agent indicated that he had inspected the fence (among other            
          items), and in the comment space he wrote, "TWO BROKEN BOARDS IN            
          REAR YARD".  We find that this evidence does not support                    
          petitioner's estimation of the value of repairing and repainting            
          the fence.  Accordingly, we allow $300 for this repair.                     
               Petitioner estimated that the cost to paint the interior of            
          the house was $1,000.  We accept this estimate; however,                    
          petitioner testified that Murray helped her do the painting.                
          Therefore, we accept only $500 as the value of Murray's services.           





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