Ragnhild A. Westby - Page 61

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          escrowed funds were not released, if at all, until sometime after           
          1990.                                                                       
               (5) Petitioner paid architect and designer fees with respect           
          to Suite 11.  Petitioner also paid for the improvements made to             
          Suite 11.                                                                   
               (6) In October 1989, petitioner’s law office was                       
          burglarized.  The burglary caused damage to the doorway, but the            
          developer refused to repair the damage.  Petitioner made the                
          necessary repairs.                                                          
               (7) By the time petitioner’s tax returns for the years at              
          issue were prepared, the developer’s interest in 1410 Energy                
          Drive had been foreclosed.  It is reasonable to assume,                     
          therefore, that all amounts paid with respect to Suite 11 during            
          the years at issue, except for the development costs that were              
          depreciated (Ex. 38-R, lines 222-228) and the interest on the               
          business loan, were deducted by Mr. Aunan as rent.  However, the            
          record does not give us sufficient information to estimate the              
          amount of rent or rent equivalent that petitioner paid during               
          1988-90.                                                                    
               We conclude that petitioner paid rent for her law office               
          during 1987 in the amount of $3,820, as shown on the chart at               
          page 79 of this opinion.  We lack sufficient information to                 
          estimate petitioner’s rent expense for 1988-90.                             








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