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respect to the inherited basis of the buildings or furnishings.
The $2,332 of depreciation petitioner claimed for 1993 consisted
of $79 for “research and development”, which respondent allowed,
and $537 for research furnishings and $1,716 for improvements,
which respondent disallowed. Petitioner was unable to remember
what specific items were being depreciated and had no records to
show basis. Respondent’s determination on these items must be
upheld on account of petitioner’s failures to identify the items
on which depreciation was claimed and to substantiate the cost of
such items.
Issue 2. Apartment Rental
During 1993, petitioner rented an apartment at 251 N. Olive,
Orange, California, which he had begun renting in 1988.
Originally, petitioner had used the apartment when he was
teaching in Orange. Orange is approximately 80 miles from
petitioner’s ranch; it takes petitioner approximately 1-1/2 to 2
hours to drive to Orange from his ranch. During 1993, petitioner
used the apartment for personal and business purposes. When
petitioner was using the apartment for business purposes in 1993,
he performed research at several libraries and met with friends
and colleagues.
During 1993, petitioner’s friend and assistant Lori used the
apartment when she was teaching in Orange. Lori did not pay rent
to petitioner for use of the apartment. Petitioner paid a total
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