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$462,737. For the taxable year ended July 31, 1992, GRC reported
an increase in its buildings and other depreciable assets to
$925,865, of which $60,755 was attributable to a building
improvement placed in service on January 2, 1992. For the
taxable year ended July 31, 1993, GRC reported an increase in its
buildings and other depreciable assets to $927,448, of which
$1,538 was attributed to building improvements placed in service
on January 1, 1993. For the taxable year ended July 31, 1994,
GRC reported a decrease in its buildings and other depreciable
assets to $923,115; however, $6,124 was shown expended for
building improvements placed in service on February 15, 1994. On
its returns for the taxable years ended July 31, 1988 through
1993, GRC deducted the following amounts for real estate taxes
paid: $0; $0; $0; $510; $6,314; and $6,934.
During the years in issue, GRC made the following payments
to Mr. Spera: In 1990, $4,786 for taxes on the "barn"; in 1991,
$3,005 for reimbursement of taxes paid on the "barn"; in 1992,
$8,054 for taxes on "Ashland". From 1989 through 1998, GRC
maintained insurance coverage with Hartford Fire Insurance Co.
On various applications for insurance, insurance policies,
amendments, and riders, the Hempstead Building was identified as
a refining operation and/or a precious metals refinery, and the
Ashland Building was identified as an office building and/or
other eligible professional offices.
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