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disallowed an additional deduction of $184,918 which petitioner
claimed on his amended return as part of the abandonment loss on
Stockton/Elsie.
Respondent also determined that petitioner had $111,229 of
cancellation of indebtedness (COD) income from the discharge of
indebtedness upon the disposition of the property. This amount
represents the advances from Angelo to petitioner for expenses
related to the cleanup.
Cirby/Sunrise Shopping Center Roof
In May 1993, petitioner received a bid from Robert Graham of
Gudgel/Yancey Roofing, Inc., for the latter to perform work on
the roof of the Cirby/Sunrise Shopping Center (Cirby/Sunrise).
The bid proposed the following work:
Remove the existing roof and haul same from the premises.
Prepare the deck for the application of the new roof.
Install a rosin sheet on the wood deck.
Nail two layers of Malarkey Roofing Products #501 SBS
base sheets to plywood deck, each layer embedded with
asphalt.
Apply one layer of Malarkey Roofing Products #601
granulated SBS cap sheet in asphalt.
Nail one layer of Malarkey Roofing Products #502 cap
sheet and one layer of #601 cap sheet to existing
stucco wall.
Remove and reinstall existing cap metal.
Replace cant strip as necessary.
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Last modified: May 25, 2011