- 8 -
or substantially prolonged its useful life. We therefore find
that because petitioner has substantiated the following capital
expenditures, they should be added to the adjusted basis of the
Longport property:
Capital Expenditures1
1985 $18,838.49
1986 1,437.26
1987 1,525.32
1988 3,358.68
1989 0.00
1990 304.07
1991 2,117.00
1992 0.00
1993 5,637.07
1994 6,056.07
Total 39,273.96
1 For a breakdown of the capital
expenditures, see the appendix.
We, however, note that this amount, like the purchase price, is
subject to reduction after considering the allowance for
depreciation.
A review of the amount realized and adjusted basis
computations (without accounting for depreciation) reveals that
petitioner sold the Longport property at a gain.4 Although this
4 There is evidence in the record suggesting that other
individuals were involved in this venture. Petitioner, however,
claims entirely for himself the loss that he has computed for the
Longport property. Because the weight of the evidence suggests
that petitioner was running the operation primarily for his own
benefit and because petitioner argues that the entire alleged
loss should be allocated to him, we agree with respondent that
the gain calculated with regard to the sale of the Longport
(continued...)
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