- 23 - other 14 condominium units was $66,915.14 Four months after the distribution, petitioner sold one of his condominium units for $67,900. Petitioner has not convinced us that the fair market value of his condominium units should be less than the average selling price of the other units sold, or $66,915. Thus, we find the fair market value of the condominiums transferred to petitioner to be $133,830. B. Basis of WSAI Shares: Debt v. Equity Respondent maintains that no loan or other value was given by petitioner to WSAI. However, the deposit records of National City Bank, where WSAI maintained a checking account, indicate that petitioner deposited $41,200 into WSAI’s account. Because the books and records of WSAI were not made available, we must look to such documentary evidence as bank statements, as well as the testimony of witnesses, in considering whether petitioner gave value to WSAI. Hagaman v. Commissioner, T.C. Memo. 1987- 549. We are satisfied that petitioner’s deposits into the WSAI account constitute value that resulted in cost to be taken into account in determining petitioner’s gain on the receipt of the condominium units. 14We exclude from this calculation the purchase price of Ackerman’s condominium units. See supra note 7.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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