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greater percentage of the value of the entire property than the
percentage allocated in the agreement. We find that respondent
correctly determined that the amount reported by ME as its basis
in land on its 1992 Federal income tax return is incorrect. We
must therefore decide whether petitioners have proved that
respondent's reallocation is erroneous.
Hollis Wilson Crenshaw, Inc. prepared an appraisal of ME's
shopping center proposal for SouthTrust Bank. It estimated the
value of the entire property at $2,800,000, and the value of the
land at $575,000. The estimates, however, include the value of:
(1) An office building (the Parrish building) on another plot of
land located adjacent to the shopping center; and (2) proposed
renovations to the existing buildings. Therefore, the appraisal
does not reflect the fair market value of the shopping center's
land and buildings at the time of acquisition.
Likewise, the parties' stipulation that the Duval County
appraiser's office appraised the value of the land at $529,688 as
of January 25, 1993, is not determinative. An estimated value of
the land absent an estimated value of the buildings thereon does
not allow us to make a conclusive apportionment of the shopping
center's purchase price under section 1.167-5(a), Income Tax
Regs.
In addition, ME's records show an entry on December 31,
1992, in the amount of $77,054 for land improvements, which
amount is not reflected on its return. Petitioners have also not
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