Legal Opinion

Alexander v. Commissioner

United States Tax Court

Decided August 6, 1991No. Docket No. 27679-89Published

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.

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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

KARL R. ALEXANDER III AND MARY T. DUPRE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Alexander v. Commissioner

Docket No. 27679-89

United States Tax Court

97 T.C. 244; 1991 U.S. Tax Ct. LEXIS 74; 97 T.C. No. 15;

August 6, 1991, Filed

Decision will be entered for the respondent.

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…

2Cases cited4 opinions

  1. Paul v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1953
  2. Endres Floral Co. v. United StatesDistrict Court, N.D. Ohio · 1977
  3. Sharp v. United StatesDistrict Court, D. Delaware · 1961
  4. Alexander v. CommissionerUnited States Tax Court · 1991

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