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6. Annual and Monthly FRV of the Residence
The annual and monthly FRVs of the residence were as
follows:
Year Annual FRV Monthly FRV
1994 $17,280 $1,440
1995 16,560 1,380
1996 17,160 1,430
1997 17,880 1,490
1998 19,020 1,585
1999 21,060 1,755
2000 26,400 2,200
7. Decedent’s Payments as to the Residence
During decedent’s leasehold, Funny Hats maintained the
residence and made capital improvements. The dollar amounts of
the capital expenses attributable to the residence were reported
on the Federal estate tax return of decedent’s estate as $3,161
in 1995, $800 in 1996, and $4,225 in 1999, for a total of $8,186.
The reported maintenance expenses for each year from 1994 through
2000 are set forth infra and aggregate $21,657.
Decedent paid (directly or indirectly) most of the expenses
connected with the residence. The partners of Funny Hats did not
want to incur out-of-pocket costs as to the residence, and they
asked decedent to pay “rent” greater than that stated in the
lease agreements to the extent that the stated rent was
insufficient to pay expenses connected with the residence.
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