Joseph A. Morcos and Joann M. Morcos - Page 14




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               Petitioners, however, are not entitled to depreciation                 
          deductions for any of their costs for grounds improvements which            
          they allocated to the carriage house.  These costs are subject to           
          the limitation imposed by section 280A(c)(5) as the grounds are             
          appurtenant to petitioners’ residence.  Sec. 280A(f)(1)(A).                 
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
                                                  Decision will be entered            
                                             under Rule 155.                          
































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