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claimed depreciation deductions for the buildings of $9,068 per
year4 (prorated for the partial year 1988). In 1994, petitioner
claimed depreciation for the buildings of $4,179.
In 1988, petitioner was issued a citation from the Borough
of Conshohocken indicating there was an actual and immediate
danger of collapse of part of the south building. In 1992, the
eastern section of the south building suffered water damage
caused by sprinklers that were set off as a result of a fire in a
building on the land adjacent to the Property. The cost of any
repairs or improvements resulting from these incidents, or the
cost of any other repairs or improvements, was not added to the
buildings’ basis.
In the fall of 1993, petitioner sought to reduce the tax
assessment on the Property. In his request for a lower
assessment (assessment request), petitioner stated that he
purchased the Property in 1988 for $373,000 and that his opinion
of the market value of the Property at the time of the assessment
request was $350,000. In the assessment request petitioner
claimed: “There are currently about 20,000 SF [square feet] of
3(...continued)
buildings at the time of purchase and did not claim separate
depreciation deductions for each building; rather, petitioner
claimed one composite depreciation deduction for all the
buildings, based on the composite basis figure.
4 The basis figure of $285,619 divided by a recovery period
of 31.5 years yields a yearly deduction of $9,067.27.
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