Dona Elizabeth Conway - Page 13

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          testimony, several of the improvements are supported by building            
          permits in evidence.                                                        
               We accept petitioner's and her former husband's testimony              
          with regard to a number of the home improvements that are claimed           
          to have been made during the years 1971 through 1986.  Set forth            
          in the schedule below, we summarize the various improvements that           
          petitioner claims were made to the home during 1971 through 1986            
          and the estimated costs that petitioner claims were incurred for            
          each improvement.  Also set forth below with regard to the                  
          improvements are the costs, if any, that we believe can be                  
          reasonably estimated and that we allow with regard to each                  
          improvement.                                                                
                                                  Petitioner's                        
                                                 Claimed        Costs                
          Claimed Home Improvements 1971-1986            Costs       Allowed          
          New electrical wiring                        $ 11,000  $ 5,000              
          New furnace and hot water heater             9,300     5,000                
          New insulation                               8,800     -0-                  
          Reconstruction of gazebo and bridge to gazebo8,000     2,000                
          Stone steps leading to the lake              1,500     -0-                  
          Pool improvements and new wrought-iron fence 8,500     5,000                
          New two-car garage and removal of old garage 46,800    20,000               
          New concrete driveway                        6,500     4,000                
          Reconstruction of second floor including a new wall12,600    10,000               
          Septic tank removal and city water/sewer hookup11,150    5,000                
          Structural improvements to doors and roof supports8,100     -0-                  
          New roof                                     10,300    -0-                  
          Interior remodeling                          4,500     -0-                  
          Dock improvements                            1,500     -0-                  
          Kitchen improvements                       7,500      -0-                   
                                   Total               $156,050  $56,000              

               Based on the evidence before us, we conclude that                      
          petitioner's tax basis in her home is $277,633, or $56,000 over             
          the $221,633 allowed by respondent.                                         





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