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In this case, we note that petitioners realized an
economic gain of approximately $65,000 when they sold their
Union County property in 1994, computed as follows:
Sale Price
5.72-acre parcel
with barns $212,500
10-acre parcel 35,000
Total price $247,500
Purchase Price
1.72-acre parcel (103,734)
Small barn (13,000)
4-acre parcel (10,000)
Large barn (30,700)
10-acre parcel 1 (25,000)
Total price (182,434)
Total economic gain 65,066
1For purposes of this calculation, we accept
petitioners' allocation of approximately one-half
of the total $48,727.50 paid for the 19.491-acre
parcel to the 10-acre portion sold in 1994.
We also note that at the time of trial, petitioners were
offering for sale at a total price of $83,000 the remaining
9.491 acres of Union County property, in which they had
an unadjusted cost basis of $23,727.50.
The economic gain petitioners realized on the sale of
the Union County property in 1994 more than offsets the
total $53,391 in operating losses they claimed during the
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