- 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 NextLast modified: May 25, 2011