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traverse any portion of property B. At the time petitioners
purchased property B, there was no road on property B.
Sometime during 1978 and 1979, petitioner husband Imre
Cziraki (Mr. Cziraki) extended the preexisting road on property
A. In 1983, Mr. Cziraki further extended the road on property A
to traverse a portion of property B. Each of these extensions of
the road was constructed by Mr. Cziraki, using his own labor and
equipment, in order to access the crops, greenhouses, and shade
houses utilized by the Rainbow Hills Nursery. The extensions of
the road were variously composed of dirt and/or gravel; no
portion of the extensions constructed by Mr. Cziraki was paved
with asphalt. The only road construction performed by outside
contractors was an asphalt extension that was constructed on or
about June 1984. Petitioners' cost basis in this road extension,
for purposes of depreciation, was $10,364. The adjusted basis of
the road extension, after adjustment for depreciation, was
$6,844, as reflected on petitioners' 1992 return.
In the later part of 1992 and the early part of 1993, the
area in which properties A and B are located experienced severe
rain storms. The storms occurred during the period of October
1992 through March 1993. A portion of the asphalt road and much
of the dirt/gravel road were damaged as a result of these storms.
The 1984 extension was also damaged by these storms. The area in
which properties A and B are situated was declared a Federal
disaster area for the period January 5 through March 20, 1993.
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