Donald D. Bowers and Deborah Bowers - Page 30

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            Gain on the Sale of the Burlington Property                                                
                  The gain from the sale of property shall be the excess of                            
            the amount realized over the adjusted basis.  Sec. 1001(a).  The                           
            adjusted basis for determining gain or loss from the sale of                               
            property is the basis (cost) of such property, adjusted as                                 
            provided in section 1016.  Secs. 1011, 1012.  Section 1016                                 
            adjustments to basis pertinent to the basis of a personal                                  
            residence include increases due to capital expenditures, and                               
            reductions due to nonrecognition of gain on a previous residence                           
            under section 1034(e).  Sec. 1016(a).                                                      
                  Petitioners (or the Trust) sold the Burlington property to                           
            the Janases for $320,000.  Out of that amount, petitioners paid                            
            $2,037 in closing costs.  Although petitioners placed at least                             
            one advertisement in the Hartford Courant in connection with the                           
            sale, the record does not establish the cost petitioners                                   
            incurred, and we decline to speculate.  Petitioners have alleged                           
            they spent a total of $24,443 for repairs performed and carpeting                          
            installed while the Trust held the Burlington property.  Most of                           
            those claimed expenditures were wholly unsubstantiated.                                    
            Respondent allowed $4,650 for repairs in recalculating                                     
            petitioners' increased deficiency.  We have no evidence to                                 
            establish any greater amount for repairs or other selling                                  
            expenses in connection with the sale of the Burlington house.                              
                  Petitioners paid Mr. Carey a total of $5,123.11 for his                              
            legal services related to acquisition of the Burlington property.                          

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