- 28 -
Petitioner’s testimony was not based on his actual recollection
of the costs incurred; rather, it was calculated to corroborate
the figure listed on the tax return.
Mark Tietig’s testimony, like petitioner’s, included
personal estimates of the actual cost to build the structure
based on a price per square foot. His testimony was not based on
his actual recollection of the costs incurred, nor did he specify
the cost of individual items26 that were computed as part of the
total cost of construction.
We find that the personal estimates provided by petitioner
and Mark Tietig are neither persuasive nor conclusive evidence of
petitioner’s actual cost to build the structure.27
26He testified regarding the different prices per square
foot for different sections of the structure (e.g., garage, first
floor, second floor) but not for individual components such as
concrete, framing, etc.
27Even if the estimated cost per square foot were close to
what a person would pay to build this particular structure, it
does not follow in this case that petitioner actually incurred
those costs. Petitioner took great pride in his ability to build
the structure at the “lowest price”. Petitioner acknowledged
that as a contractor, he saved money by doing some aspects of the
construction, and much of the procurement of materials, himself.
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