- 5 - a loan of $500,000 from a bank, which was secured by a first mortgage. In a document from the loan officer to the bank’s loan committee recommending approval of the loan, the loan officer stated: Although property in question is an old one and in considerable need of repair, the property should be desirable when rehabilitated and will have substantial value. With the potential rental income combined with the rent saving of Julicher, cash flow should be adequate to service the debt. Petitioner used the balance of the loan over the purchase price to make repairs to the buildings on the Property. Petitioner did not increase his basis in the buildings by the amount of these repairs. Petitioner bought the Property because he had lost his lease on a previous location where his corporation conducted its business, and the buildings on the Property were suitable for use in the corporation’s business. Petitioner allocated $107,759 of the purchase price to the land and $285,619 to the buildings. Petitioner took depreciation deductions on the buildings beginning in April 1988 using a basis for depreciation of $285,619, the straight-line method, and a recovery period of 31.5 years.3 Through 1993, petitioner had 2(...continued) petitioner as the only purchaser. 3 Petitioner did not allocate basis individually among the (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011