- 2 -
Respondent determined a deficiency in petitioners’ 1998
Federal income tax in the amount of $13,854. After a concession
by petitioners, the issue this Court must decide is whether
petitioner Shirley Cox (petitioner) is entitled to deduct the
cost of removing and replacing the roof-covering material and
related expenses on her commercial building.
Some of the facts in this case have been stipulated and are
so found. Petitioners resided in Belmont, California, at the
time they filed their petition.
During 1998, petitioner owned a one-half interest in a
commercial building (building) at 590 Taylor Street, Belmont,
California. The building contains 23,000 square feet of offices
and a warehouse.
The building was rented to Environmental Care Inc.
(Environmental). One of Environmental’s jobs was to provide all
the Christmas decorations for the World Trade Center in San
Francisco, California. During the year in issue, the roof
leaked, damaging Environmental’s materials. Environmental’s
personnel complained to petitioner and even threatened legal
action.
Petitioner hired Armstrong Roofing (Armstrong) to stop the
leaks and install a foam roofing system. The acting roof
superintendent (superintendent) examined the roof and found it
“basically * * * intact” except for one location “where water was
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011