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We do not have sufficient information to estimate how much
petitioners paid for the storage addition that was completed in
1982. Also, petitioners have failed to show that they did not
include the cost of the storage addition on the depreciation
schedule attached to their 1982 return, for which respondent
already concedes an allowance for depreciation. Finally,
petitioners have not shown that they did not fully depreciate the
cost of the storage addition before 1985. Thus, petitioners may
not increase their basis in the Hoefgen Avenue property for 1985
or any later year to include any costs of building the storage
addition.
B. Whether Petitioners Have Basis in the Hoefgen Avenue
Property for Outdoor Advertising Signs
Petitioners contend that the two outdoor advertising signs
on the Hoefgen Avenue property had a future contract value of
$130,000 and that we should increase their basis in the Hoefgen
Avenue property by that amount. We disagree.
The basis of property is generally its cost. See sec. 1012;
Better Beverages, Inc. v. United States, 619 F.2d 424, 428 (5th
Cir. 1980); Winn-Dixie Montgomery, Inc. v. United States, 444
F.2d 677, 683-684 (5th Cir. 1971). Future contract value is not
the cost of the two outdoor signs.4 There is no evidence of the
4 Future contract value is not a proper grounds for
computing gain. See sec. 1012; Better Beverages, Inc. v. United
States, 619 F.2d 424, 428 (5th Cir. 1980); Winn-Dixie Montgomery,
(continued...)
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