David Dobrich and Naomi Dobrich - Page 18

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          that petitioners did not identify the Pleasant Hill or Skyland              
          properties as replacement property within the time period                   
          required by section 1031(a)(3)(A).  Accordingly, the gain                   
          realized from the sale of the Antioch property is recognizable.             
               In the notices of deficiency, respondent determined the gain           
          realized on the sale of the Antioch property without regard to              
          petitioners' basis in the property.  Section 1001 provides that             
          the gain from the sale of property is the excess of the amount              
          realized over the adjusted basis.  The adjusted basis of property           
          is its basis (cost) as determined under section 1011 and as                 
          adjusted by section 1016.  Sec. 1012.  The basis is adjusted for            
          the costs of improvements and betterments made to the property.             
          Sec. 1016(a)(1); sec. 1.1016-2(a), Income Tax Regs.                         
               Petitioners paid $300,000 for 137 acres of the Antioch                 
          property and sold 117 acres of the property in the transaction at           
          issue in this case.  Petitioners' original basis in the 117                 
          acres, based on the $300,000 purchase price, is $256,204, as                
          conceded by respondent.  Petitioners also expended approximately            
          $30,000 in engineering and consulting costs to improve the 137              
          acres of the Antioch property.  We find that petitioners' basis             
          in the 117 acres of the Antioch property is $281,825, and their             
          gain realized is $3,687,175 ($3,969,000-$281,825).                          
          Installment Method                                                          
               Petitioners argue that they are entitled to report any gain            
          that they must recognize from the sale of the Antioch property in           



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