- 4 - II. Disputed Adjustments A. Sale of Mukilteo Condominiums On or about November 13, 1981, petitioner purchased five condominium units located in Mukilteo, Washington (the five units). Petitioner owned those units as rental properties. On or about January 25, 1989, petitioner transferred the five units to Great American First Savings Bank (Great Bank) in conjunction with the settlement of potential litigation regarding purported soil erosion affecting those properties. Attached to the 1989 tax return is a “Statement of Involuntary Conversion”, which relates to the five units. That statement shows a gain in the amount of $89,3391 on the disposition of the five units and provides that the taxpayer intends to acquire replacement property and “to defer the gain realized by the involuntary conversion” of the five units. In the notice of deficiency, respondent adjusted the amount realized on the sale of the five units by increasing the amount of the settlement proceeds from $206,009 to $210,500 and adjusted petitioner's adjusted basis in the five units by decreasing petitioner's initial, cost basis from $228,067 to $222,242. Respondent determined that, after taking into account depreciation and other items, petitioner realized gain on the 1 For simplicity, figures have been rounded to the nearest dollar, and, thus, in some of the calculations to follow, there are some minor discrepancies.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011