- 2 -
(1) Are petitioners entitled to the depreciation deductions
claimed in Schedules C of their returns for the years at issue?
We hold that they are not.
(2) Are petitioners entitled to the repair and maintenance
expense deductions claimed in Schedules C of their 1994 and 1995
returns? We hold that they are not.
Background
Many of the facts have been deemed stipulated for purposes
of this case pursuant to Rule 91(f).2
Petitioners resided in Montgomery, West Virginia, at the
time the petition was filed.
Petitioners timely filed joint returns, Forms 1040, for the
years at issue.
On July 2, 1987, petitioners purchased lots 31, 32, 33, and
34, section 5, Adena Village, located in Mt. Carbon, West Vir-
ginia, for $13,116.50. They personally constructed a building
(Building) on those lots, having spent $23,809.90 during 1987 and
1(...continued)
the notice of deficiency (notice) with respect to (1) the deduc-
tions that they claimed in Schedule C of their 1993 tax return
(return) for $200 of personal life insurance premiums and for
$2,400 of alleged pension and profit-sharing plan contributions
and (2) the respective charitable contribution deductions that
they claimed in Schedules C of their 1994 and 1995 returns that
should have been reported in Schedules A, Itemized Deductions, of
those returns.
2All Rule references are to the Tax Court Rules of Practice
and Procedure. All section references are to the Internal
Revenue Code in effect for the years at issue.
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011