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placed in service during 1986 in excess of the $22,102 to which
the parties stipulated, they argue that they should be allowed to
estimate from memory their bases in the properties that they
placed in service during that year and that the Court should
sustain that estimate. On the record before us, we decline to do
so. Petitioners have failed to establish what properties they
placed in service during 1986 or that their bases in whatever
properties they did so place in service exceeded the $22,102 to
which the parties stipulated, and the present record does not
provide enough reliable information to enable us to make a
reasonable estimate of the petitioners' bases in the properties
with respect to which they claim depreciation deductions for the
years at issue. See Coloman v. Commissioner, 540 F.2d 427, 431-
432 (9th Cir. 1976), affg. T.C. Memo. 1974-78; Vanicek v. Commis-
sioner, 85 T.C. 731, 742-743 (1985).
Based on our review of the entire record before us, we find
that petitioners failed to prove that their bases in the proper-
ties at issue exceeded the $22,102 to which the parties stipu-
lated. We therefore shall not allow petitioners to deduct for
any of the years at issue any amount under section 167(a) in
excess of that amount calculated by taking account of those
stipulated bases.
General Business Credit Carryforward
In addition to claiming depreciation deductions for the
years at issue with respect to the properties that they claim
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