- 19 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011