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of all improvements to the Hoefgen Avenue property was $306,522
as of June 8, 1990. He did not estimate how much petitioners
spent to build the storage and office additions.
Petitioners point out that the Bexar County property tax
statements for the Hoefgen Avenue property show that the
improvements to that property were worth $112,020 in 1984 and
$158,800 in 1985 and 1986. Petitioners also point out that
petitioner signed a building permit which states that the
estimated cost for the office addition was $10,400. These facts
are not sufficient evidence of basis.
Respondent contends that the record provides no basis to
estimate petitioners’ costs for the storage and office additions.
We disagree. We may estimate petitioners’ basis in those
additions “bearing heavily * * * upon the taxpayer whose
inexactitude is of his own making." See Cohan v. Commissioner,
39 F.2d 540, 544 (2d Cir. 1930), affg. in part and remanding 11
B.T.A. 743 (1928); see also Bayou Verret Land Co. v.
Commissioner, 450 F.2d 850, 858 (5th Cir. 1971), affg. 52 T.C.
971 (1969). We estimate that petitioners paid $20,000 to add the
office and that it was completed in 1984. Petitioners may
increase their basis in the Hoefgen Avenue property for the
office addition using a 15-year useful life and a placed-in-
service date of July 1984.
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