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not even have copies of their income tax returns showing
depreciation. Petitioners did not have proof of purchase of the
Mullen Avenue property nor of any subsequent capital
improvements. Petitioners had a schedule prepared by their tax
return preparer which showed purported capital improvements of
$130,550. The listed items on that schedule totaled $65,275 and
the return preparer apparently doubled that amount to $130,550.
Petitioner admitted the error at trial. The schedule is also
suspect because it contains items not capital in nature. It is
further suspect in that most items are rounded to the nearest one
hundred dollar amount. This schedule does not persuade us to
adjust respondent’s generous computation of capital improvements.
Nor have petitioners shown error in the computation of
depreciation which respondent had to undertake because of the
failure of petitioners to provide records. Respondent’s
determination on the capital gains issue is sustained, except as
set forth below.
Respondent did not have petitioners’ Escrow Closing
Statement for the sale of the Mullen Avenue property when
respondent made the computation in the notice of deficiency.
This Court has stated that it has always been recognized that all
expenses of sale enter into the computation that results in the
determination of a gain. Chapin v. Commissioner, 12 T.C. 235,
238 (1949), affd. 180 F.2d 140 (8th Cir. 1950). The Escrow
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