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That description of the standard is consistent with that
articulated by the Board of Tax Appeals in Estate of Manierre v.
Commissioner, 4 B.T.A. 103, 106 (1926):
A repair is an expenditure for the purpose of keeping
the property in an ordinarily efficient operating
condition. It does not add to the value of the
property, nor does it appreciably prolong its life. It
merely keeps the property in an operating condition
over its probable useful life for the uses for which it
was acquired. Expenditures for that purpose are
distinguishable from those for replacements,
alterations, improvements or additions which prolong
the life of the property, increase its value, or make
it adaptable to a different use. * * *
There is no dispute in this case that the expenditures in
question were necessitated by an accident that occurred in August
1994. One of petitioner’s drivers was driving petitioner’s truck
when it jackknifed and slid into a ditch causing substantial
damage to the truck. Petitioner, appearing pro se, testified at
trial, in response to a question from the Court, that the
expenditures were “to get [the truck] * * * to its original shape
before it was rolled.” Petitioner further testified that he
consulted with his return preparer about the expenditure and was
informed that “as long as * * * [the truck] wasn’t better than it
was, just put * * * [the truck] back so it was in workable
shape”, the expenditure was deductible. Respondent offered no
evidence to refute petitioner’s testimony, which we found to be
credible.
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