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the zoning restrictions were depressing the value of Calvine
120/140. Petitioner filed a letter with the County outlining his
plans to subdivide Calvine 120/140 into 947 single-family lots
and other sites.
On his 1995 tax return, petitioner deducted real estate
property taxes of $26,985 for Calvine 120, and $35,180 for
Calvine 140. Respondent disallowed the deduction and determined
that the amounts were capital expenditures.
Payment to Consolidated Electrical Distributors
On December 29, 1995, petitioner paid Consolidated
Electrical Distributors $7,472 from his Greenhaven Plaza bank
account. On his 1995 tax return, petitioner deducted this amount
as a repairs expense with respect to his Greenhaven property.
Respondent disallowed this amount because petitioner did not
establish the amount as an ordinary and necessary business
expense.
OPINION
I. Evidentiary Issue
As a preliminary matter, petitioner objects to the admission
of the preliminary change of ownership report (the report) as
hearsay. At trial, the Court admitted the exhibit under
advisement, reserving ruling on the objection until parties
briefed the issue.
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