Donald D. Bowers and Deborah Bowers - Page 32

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            cost incurred in acquiring the Burlington property or a capital                            
            expenditure; therefore, it cannot be included.                                             
                  Petitioners also argue that Mr. Bowers had a carryover basis                         
            of $182,531,25 or, alternatively, that Deborah received a gift                             
            from Mr. Bowers with a carryover basis of $91,265.  This,                                  
            petitioners argue, is in addition to the other items of basis                              
            already mentioned, except to the extent that a portion of the                              
            first mortgage would be double-counted.  The former argument is                            
            the equivalent of saying that Mr. Bowers had a 100-percent                                 
            interest in the Burlington property just prior to Florence's                               
            transferring title, that he is entitled to 100 percent of the                              
            alleged carryover basis in the Burlington property at that time,                           
            and that he continued to have an interest after Mr. Carey                                  
            acquired title for the Trust.  The alternative argument is                                 
            similar, except that Mr. Bowers purportedly gave a one-half                                
            interest of the alleged carryover basis to Deborah.                                        
                  Respondent's position is that there is no carryover basis                            
            from Mr. Bowers.  Respondent argues that Mr. Bowers did not have                           

            25 Petitioners on brief calculated this carryover basis as                                 
                        Original purchase price             $125,000                                   
                        New well system                     40,000                                     
                        Original landscaping                7,500                                      
                        Initial improvements                10,031                                     
                              Total                         $182,531                                   
            The evidence of record does not support these figures.                                     

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