Jeffrey and Karen Winter - Page 16




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          the purchase of the hotel was decreased by $271,473.95.6  On the            
          basis of the evidence in the record, we find that the legal and             
          consulting fees arose out of, were incurred in connection with,             
          and were directly related to, the acquisition of the Truckee                
          Hotel, a capital asset.  Accordingly, we hold that the fees at              
          issue must be capitalized.                                                  

                                             Decision will be entered                 
                                        for respondent.                               
























               6The settlement agreement essentially resulted in a reduced            
          purchase price for the Truckee Hotel.  It appears that the                  
          reduction in the purchase price would decrease petitioners’ basis           
          in the hotel.                                                               





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