George Tsakopoulos and Drousoula Tsakopoulos - Page 8




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          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.                                                                       





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