- 45 - Tahiti Property With regard to petitioners' Tahiti Property, our conclusions are just the opposite. Petitioners' Tahiti Property has inherently associated with it extensive recreational and personal aspects. Petitioners have not satisfied their burden of proof that the Tahiti Property was held and managed by them for anything other than personal reasons. Rule 142(a). Petitioners did not maintain complete and adequate records with regard to expenditures made on the Tahiti Property. Petitioners’ assertion as to significant appreciation in the value of the Tahiti Property is neither credible nor persuasive. Petitioners claim that, as a result of their efforts and improvements, by 1994, the fair market value of the Tahiti Property increased to $3.7 million and that, after their purchase costs of $989,000 and additional costs of $597,000, for total alleged cash expenditures of $1,760,000, petitioners have realized on paper an economic gain of $1,940,000 in connection with the Tahiti Property. No credible evidence supports either the amount or nature of the claimed total expenses petitioners incurred on the Tahiti Property, nor the fair market value of the Tahiti Property. We conclude that, during the years in issue, petitioners' ownership and management of the Tahiti Property constituted a personal activity with respect to which petitioners' expensesPage: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
Last modified: May 25, 2011