- 8 - the proposal did not include the work of applying one Malarkey Roofing Products #502 cap sheet and one #601 sheet to existing stucco walls. In September 1994, petitioner paid Gudgel/Yancey Roofing $27,000 for this work. Mr. Graham inspected the completed work, which had a warranty of 10 years. On his 1994 tax return, petitioner deducted $65,319 as repairs to Carmichael Village. Respondent disallowed $32,7325 and determined that these amounts were capital expenditures. Payment to Royal Roofing, Inc. In November 1995, petitioner paid $30,000 to Royal Roofing, Inc. On his 1995 tax return, petitioner deducted $84,815 as repairs for Carmichael Village. Respondent reduced this amount by $72,887 and determined that petitioner had not established that the expenses were ordinary and business expenses. Of this amount, respondent determined that the $30,000 paid to Royal Roofing was not a “repair” because petitioner had not provided sufficient documentation to establish the nature of the work. 5 This amount represented $27,000 paid to Gudgel/Yancey Roofing plus $5,732 of other repairs, which the parties have stipulated are not deductible as repairs or capital items in 1994.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011