Henry A. Julicher - Page 5




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          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...)           






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