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the work provided a functional improvement to the roof,
materially added to the value of the property, or would
appreciably prolong the life of the roof. Id. In the instant
case, Mr. Graham credibly testified that the new roof had a 10-
year warranty, prolonging the life of the property.
Additionally, in Vanalco, the work on the roof was performed
during ordinary maintenance which occurred almost every year. In
the instant case, however, no evidence was presented to indicate
that the work performed on the roof was of a recurring nature.
Although petitioner replaced the roof of 10 percent of the
entire shopping center, we note that the entire builtup roof of
that section was replaced. This section encompassed the roof
above 12 separate suites. After considering the evidence, we
hold that the cost of the work performed on the roof must be
capitalized because of the substantial nature of the work
performed and the work appreciably prolonged the life of the
roof.
C. Payment to Royal Roofing, Inc.
Respondent argues that petitioner’s $30,000 payment to Royal
Roofing, Inc., should not be allowed as a deduction for 1995
because petitioner presented no evidence as to the business
purpose of the payment. Petitioner argues that he established
the business nature of this payment and it is deductible.
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