Alexander v. Commissioner
United States Tax Court
Ts purchased property on November 30, 1984, and promptly began to renovate the building, a "certified historic structure." The renovations were completed in 1985. Ts completely modified the first floor, previously uninhabitable, so as to convert it into a one bedroom apartment. The renovations of the upper floors, inhabitable when the property was purchased, were considerably less extensive. Ts occupied the upper floors as their residence, and rented the first floor.
Read the full summary
Ts purchased property on November 30, 1984, and promptly began to renovate the building, a "certified historic structure." The renovations were completed in 1985. Ts completely modified the first floor, previously uninhabitable, so as to convert it into a one bedroom apartment. The renovations of the upper floors, inhabitable when the property was purchased, were considerably less extensive. Ts occupied the upper floors as their residence, and rented the first floor. The basis of the building was $ 68,795, of which $ 21,607 was allocable to the first floor. The cost of renovating the entire…
1Opinion of the Court
OPINION
Raum, Judge:
Respondent determined a deficiency in income tax for 1985 in the amount of $4,717 against Karl R. Alexander III (Alexander) and Mary T. Dupre (Dupre), husband and wife, who had filed a joint return for that year. Respondent also determined a deficiency in the amounts of $663 and $1,824 against Alexander for his 1982 and 1983 taxable years, respectively, and against Dupre in the amount of $2,487 for her 1982 taxable year. They were single individuals during the earlier taxable years and had filed separate returns for those years. The only matter in dispute is whether…
2Cases cited3 opinions
- Paul v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
- Endres Floral Co. v. United StatesDistrict Court, N.D. Ohio · 1977
- Sharp v. United StatesDistrict Court, D. Delaware · 1961
3Cited by3 opinions
- Colorado, Ltd. v. CommissionerUnited States Tax Court · 1992
- Alexander v. CommissionerUnited States Tax Court · 1991
- Dennis v. CommissionerUnited States Tax Court · 1993