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The parties have stipulated that petitioner received $14 in
interest income in 1991.
The parties have further stipulated that petitioner sold the
Crazy Horse property in 199111 for a gross sales price of
$155,000. Respondent determined in the deficiency notice that
petitioner had income in that amount from real estate sales.
Petitioner testified that his basis in the property was "$186,000
or $183,000" but has provided no evidence to corroborate that
statement. Respondent, however, introduced into evidence a
personal financial statement prepared and signed by petitioner on
March 11, 1988, in which petitioner represents that his cost was
$90,000 for real property at "4519 Route 38 East" that was
acquired in 1987. Since the parties have stipulated that the
Crazy Horse property was located at the foregoing address and was
purchased by petitioner on July 31, 1987, we accept the $90,000
figure as petitioner's cost for the Crazy Horse property.
Assuming that the property was 31.5-year property and was placed
in service on or about July 31, 1987, we estimate that petitioner
would have been entitled to depreciation of as much as $11,190
during the period the property was held. We accordingly reduce
our estimate of petitioner's basis by that amount, for an
estimated basis of $78,810. Petitioner offered into evidence,
and we hereby admit, the June 11, 1991, settlement statement from
11 Based on the record in this case, we find that the date
of sale was June 11, 1991. See infra note 12.
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