Donald D. Bowers and Deborah Bowers - Page 31

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            Some of this expense was related to acquisition of the Burlington                          
            property from Florence, and some was related to its sale.  While                           
            fees incurred in the acquisition of property are part of basis,                            
            and those incurred during sale are a reduction in the amount                               
            realized, either treatment reduces the amount of petitioners'                              
                  Petitioners paid $20,000 in cash, plus releasing Florence                            
            from the mortgage obligations, in consideration for Florence's                             
            transferring title to the Trust.  On July 26, 1989, when Florence                          
            transferred title, the Burlington property was subject to the                              
            three outstanding mortgages.  The record is silent as to the                               
            exact amount of these debts on that date.  However, petitioners                            
            later made the following payments on these mortgages:                                      
                  Date                 Amount                  Lender                                  
                  Sept. 18, 1989  $32,376.89          United Bank & Trust Co.                          
                  Oct. 17, 1989    2,000.00           Connecticut National Bank                        
                  Dec. 8, 1989      67,598.56         Shawmut Bank                                     
                  Dec. 8, 1989      33,367.72         Connecticut National Bank                        
            These payments were a cost of acquisition as discussed below.                              
                  Petitioners argue that their basis in the Burlington                                 
            property should include $50,000 for the mortgage from Florence to                          
            Mr. Bowers that was released.  This debt was voided by the                                 
            Bankruptcy Court on July 6, 1987, as well as ordered released by                           
            the Superior Court on January 31, 1989.  See supra notes 2, 3.                             
            Mr. Bowers' inability to collect on this purported debt is not a                           

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