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any such showing. In fact, petitioner neither elicited any
testimony in support of his counsel’s statement, nor attempted to
introduce any other type of supporting evidence.
Second, even if the construction costs had any bearing on
TBP’s depreciable basis, we disagree with petitioner that these
costs aggregated $926,500. We do not rely on petitioner’s
testimony on this subject for it is vague, uncorroborated, and
self-serving. See Diamond Bros. Co. v. Commissioner, 322 F.2d
725, 730-731 (3d Cir. 1963), affg. T.C. Memo. 1962-132; Tokarski
v. Commissioner, 87 T.C. 74, 77 (1986). The only other evidence
on this subject, namely, the testimony of Mr. Salmon, does not
support petitioner’s claim to the $926,500 basis. Mr. Salmon
testified that the estimated cost of the buildings was $413,500,
a figure that was inflated by $7,237 in that it incorrectly
included the cost of the hay barn. The cost of the hay barn
should not have been included in his calculation because the hay
barn was constructed before even Alpha acquired the land. We
also note an inconsistency between the cost factors used by Mr.
Salmon to perform his calculations and the factors used by
respondent's expert, Harriett Watts, to arrive at her conclusion
that the estimated cost of the buildings was $286,258. Although
both experts used the same valuation guide to perform their
calculations, only Ms. Watts applied the cost factors for Newark,
New Jersey, a city which is proximate to the situs of the farm.
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