Meredith and Shirley A. White - Page 3




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          $4,038.92 during 1988 for materials used in that construction.              
          In January 1989, approximately one-half of the Building was                 
          placed in service as a car wash known as Sand M Auto Cleaning               
          Service (car wash business).  During 1993, petitioners had no               
          employees and operated their car wash business themselves.                  
               Petitioners first claimed a depreciation deduction with                
          respect to the Building in their 1989 return.  They determined              
          the depreciation deductions claimed in that and subsequent                  
          returns, including their returns for the years at issue, on the             
          basis of a claimed original cost basis in the Building of                   
          $55,000.  That claimed basis represented the fair market value of           
          the Building, including the cost of the materials and petition-             
          ers’ labor, as estimated in 1989 by petitioners and a friend.               
               During 1994, petitioners expended $3,074 to purchase and               
          install two doors and four pieces of glass into 64- by 96-inch              
          openings in the portion of the Building that they were not using            
          as a car wash (unfinished portion of the Building).  During 1995,           
          petitioners spent $2,918 on additional construction with respect            
          to the unfinished portion of the Building.  The unfinished                  
          portion of the Building was not finished during the years at                
          issue.  As of the date of the trial, that portion of the Building           
          was still under construction and had never been used or rented.             
          Petitioners intend to finish the unused portion of the Building             
          when they have enough money to do so.  When that portion of the             






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