Charles R. Bowden and Sue I. Bowden - Page 36

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            evidence, reflects that their basis in the property would have                             
            originally been more than $1.75 million.  Therefore, we hold that                          
            petitioners’ basis, as determined by respondent, was understated.                          
            Accordingly, we hold that petitioners’ basis in the Crestwood                              
            property was $2 million.  Cohan v. Commissioner, 39 F.2d 540 (2d                           
            Cir. 1930).  Accordingly, petitioners must recognize $525,000 of                           
            gain on the transfer of the property to Prudential Bancorp.                                
            E.  Unreported Income                                                                      
            1.  Salaries                                                                               
                  Petitioners have stipulated that they failed to report                               
            salaries and self-employment income in varying amounts for 1986                            
            and 1989.  Those amounts will be considered in the Rule 155                                
            computation.                                                                               
                  Petitioners reported $42,000 of income subject to Social                             
            Security on Schedule SE of their 1986 Federal income tax return.                           
            Respondent contends that Mrs. Bowden omitted $18,000 in                                    
            compensation from PWIC in the 8-month period ending December 31,                           
            1986.  Petitioners contend that the $18,000 was, in fact,                                  
            included in the $42,000 already reported on the aforementioned                             
            Schedule SE.  From the record in this case, we have no reason to                           
            doubt petitioners’ testimony that the $18,000 amount was already                           
            included in the total of $42,000 that respondent determined                                
            should be reported.  Accordingly, the $18,000 is deemed to be                              
            part of the $42,000 already reported by petitioners.                                       





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