Caralan Trust, et al. - Page 14




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          C E Shirley Trust, respectively.  After taking into account a               
          deduction of $100 for a personal exemption, it reported a loss of           
          $100 and no income tax due.                                                 
               The property involved in the rental activity was used by the           
          J. Shirleys during 1995 as their personal residence.  With                  
          respect to the rental activity, Caralan Trust reported gross                
          income of $42,000 and expenses of $66,165, which gave rise to the           
          claimed rental activity loss of $24,165.  Among the expenses                
          claimed by Caralan Trust in computing that loss were personal               
          expenses of the J. Shirleys.  Caralan Trust also reported (but              
          did not claim in computing adjusted total income) an allowance              
          for depreciation in the amount of $19,896 on account of property            
          that the J. Shirleys used as (and in) their personal residence.             
          The $42,000 reported as rental activity gross income is the same            
          amount claimed by Alexion on the Alexion 1995 return as rent paid           
          for business property.  Caralan Trust reported $19,896 as the               
          J. Shirley’s share of the depreciation deduction computed by                
          Caralan Trust.                                                              
          C E Shirley Trust                                                           
               C E Shirley Trust is a trust created by the C. Shirleys.               
          C E Shirley Trust was created on July 1, 1995.                              
               For 1995, Curtis E. Shirley made a return of Federal income            
          tax for C E Shirley Trust on Form 1041, U.S. Income Tax Return              
          for Estates and Trusts (the C E Shirley Trust 1995 return).  He             






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