- 21 - 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 testifiedPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011