James L. Christian - Page 4




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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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