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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
follows:
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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