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on their 1992 Federal income tax returns for the gift of the
gifted Litton property.5
Respondent determined that the fair market value of the
gifted Litton property on December 17, 1992, was $800,000.
The Bates Center
The Bates Center consists of a 10,022 square foot building
(the Bates Center building) located on 50,507 square feet of land
(the Bates Center land) on the 1700 block of 46th Street in
Lubbock, Texas. The Bates Center land was zoned R-2 residential
with a church variance.
The Bates Center land consists of six lots. Five of the
lots were contiguous (the 5 lots). Three of the five lots were
located on 45th Street. The westernmost lot was approximately 60
feet from Avenue S, and the easternmost lot was approximately 300
feet from Avenue Q. Two of the five lots were located on 46th
Street. The westernmost lot was approximately 120 feet from
Avenue S, and the easternmost lot was approximately 300 feet from
Avenue Q. The other lot (the excess lot) was noncontiguous with
the five lots and was located across the street from the five
lots on the northeast corner of the intersection of Avenue S and
45th Street.
5 None of the parties explained why Mr. and Mrs. Talkington
deducted $900,000 rather than $902,500 on their 1992 Federal
income tax return.
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