Eli T. Sleiman, Jr. and Janie L. Sleiman, et al. - Page 19

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          established whether the Parrish building was purchased during               
          1992 and, if so, for how much.  They have failed to address                 
          whether or not these amounts should be taken into account in                
          apportioning the value of the shopping center between land and              
          depreciable property.                                                       
               After reviewing the record, we find that petitioners have              
          failed to meet their burden of proving that respondent's                    
          reallocation of ME's basis in land and depreciable real property            
          is erroneous.  Rule 142(a).  The evidence does not show that the            
          proportionate value of the shopping center's land acquired by ME            
          during 1992 is accurately reflected in the purchase and sale                
          agreement.  Due to their failure to produce probative evidence              
          concerning the value of the property at the time of acquisition,            
          petitioners have not carried their burden of showing error in               
          respondent's allocation.  Among other things, petitioners have              
          failed to establish whether ME's postacquisition improvements or            
          its costs of acquiring the Parrish building should be taken into            
          account.  We hold that respondent must be sustained on this                 
          issue.                                                                      














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