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The remaining portion of the adjustment is attributable to a
$3,366 net disallowance of deductions for rental expenses claimed
on petitioner's 1993 Schedule E. Petitioner has failed to
substantiate the rental expenses, specifically those relating to
the payment of insurance, repairs, supplies, and gas, which
respondent disallowed.
Petitioner argues that, in determining the amount of
petitioner's cash expenditures for purposes of reconstructing her
income, the parties stipulated that petitioner spent $5,893 on
property improvements to the house, and that therefore petitioner
is entitled to an additional depreciation deduction under section
168.
We do not agree with petitioner. Respondent allowed
petitioner a 1993 depreciation deduction for the house that is
$618 greater than what she claimed on Schedule E. Although
the record does not disclose how this increase was computed in
its entirety, we do have in evidence Ms. Dickerson's worksheet
describing and itemizing the expenditures for the total
improvements of $5,893. It appears that Ms. Dickerson allocated
these expenditures between the rental and personal use portions
of the house and allowed an additional depreciation deduction
for the portion of the year that petitioner owned the house.
Petitioner has not shown that she is entitled to any additional
depreciation deduction for the house.
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