- 10 - 1997, petitioners reported nonpassive income or loss relating to TGR II in the partnership income section. OPINION A. Whether Petitioners Have a Basis of $233,408 in the Storage and Office Additions to the Hoefgen Avenue Property Petitioners contend that they paid $233,408 in the early 1980's to add storage and office space to the Hoefgen Avenue property. Respondent contends that petitioners have failed to show that they are entitled to any basis in the additions to the Hoefgen Avenue property.2 Petitioners rely in part on Zamora’s and Neal’s testimony to substantiate their basis for the storage and office additions.3 Zamora credibly testified that he designed and oversaw the construction of the storage addition at the Hoefgen Avenue property in 1981 and 1982, and the office addition in 1983 and 1984. Zamora testified that the storage addition was not significant because petitioners did not change the exterior or roof structure of the building. Zamora did not testify about the cost of the additions. Neal estimated that the replacement cost 2 Respondent allowed depreciation deductions for 15-year property costing $22,895, for 5-year property costing $12,083, and for 3-year property costing $48,044, which petitioners reported on their 1982 return was placed in service in 1981 and 1982. 3 Petitioners offered no evidence to prove their contention that they lost petitioner’s records when moving to the Jones Maltsberger Road property.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011