- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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