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their cost basis of $165,000 by the depreciation deductions
allowed or allowable, whichever is greater, for each of the years
1993, 1994, and 1995 during which petitioners rented the condo.
We turn first to petitioners’ position regarding the im-
provements that they claim they made to the condo. In support of
that position, petitioners rely on Ms. Stoddard’s testimony,
certain checks payable to Edensaw Woods, Peter Jones, Brian
Callahan, and Spa Shops and on the 1993 loan application.
Ms. Stoddard testified that the checks payable to Edensaw
Woods represented disbursements for “lumber and specialty wood
that we had put into the condominium in the form of ceiling
timbers and a bookcase around the fireplace.” However, the
following handwritten notation appears on one of those checks:
“Quissett Charters”. Ms. Stoddard testified that the checks
payable to Peter Jones and Brian Callahan represented disburse-
ments “for wages paid to them to build this bookcase and sur-
rounding hearth–-or it’s not a hearth, around the fireplace.” It
is not clear from Ms. Stoddard’s testimony or from the checks on
which petitioners rely what she meant when she testified that the
wood purchased from Edensaw Woods was “put into the condominium
in the form of ceiling timbers”. Nor is it clear from Ms.
Stoddard’s testimony or from the checks on which petitioners rely
that the bookcase which was built around the fireplace in the
condo constitutes an improvement to the condo. Assuming arguendo
that we were able to find on the instant record that the results
of the work in the condo about which Ms. Stoddard testified
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