- 13 -
at the date of conversion was substantially less than
petitioners’ purported FMV of $480,000. Further, the fact that
the property eventually sold for $435,000 in December 1996
indicates there had been little if any change in its FMV from
July 1995 until the date of its sale.
For the above reasons, we hold that the FMV of the Stewart
property in July 1995 was $435,000, and, therefore, petitioners
did not sustain a loss on the subsequent sale of the Stewart
property on December 27, 1996, for $435,000. Accordingly, we
sustain respondent’s determination on this issue.6
We have considered all of the other arguments made by the
parties, and, to the extent that we have not specifically
addressed them, we conclude they are without merit.
6 Accordingly, petitioners have a gain in 1996 in the
amount of $5,999 calculated as follows:
Sales Price $435,000
Less Adjusted Basis ($435,000 FMV
less $5,999 depreciation) 429,001
Total Gain 5,999
However, at trial respondent waived any increased deficiency for
1996.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011