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square feet: The first floor is primarily of concrete
construction; the second floor is of timber construction; and the
third floor is of timber construction on the outside with cedar
interior wood. From August 1996 to date, petitioners have
resided in the Ashland Building's third floor living quarters;
and as of February 1998, the first floor of the Ashland Building
is being used as an operational precious metals melting facility.
Petitioners did not report any rental income on their 1987
through 1995 tax returns. From 1987 through 1990 and 1992
through 1997, petitioners paid all property tax bills on the
Ashland property as follows: $221 in 1988; $2,116 in 1989;
$2,422 in 1990; $3,326 in 1992; $3,446 in 1993; $3,448 in 1994;
$3,487 in 1995; $3,409 in 1996; and $3,538 in 1997. For the
period July 1, 1988, through June 30, 1990, petitioners paid
$1,247, $2,419, and $2,803, respectively, for school taxes on the
Ashland property.
For its taxable years ended July 31, 1988 through 1990,
GRC's Forms 1120 report other assets relating to construction in
progress in the respective amounts of $233,784, $281,785, and
$381,300. For the taxable year ended July 31, 1991, GRC reported
only $7,059 in other assets relating to construction in progress.
Its buildings and other depreciable assets were increased from
$397,591 to $860,328. Under its depreciation summary, GRC showed
a building placed in service on August 1, 1990, with a basis of
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