- 98 - mortgage in his name which he paid. Petitioner asserts that respondent did not cross-examine him on his testimony nor offer any evidence that petitioner did not pay for the property in 1984. Respondent contends that petitioner has failed to establish the cost of the property or that he used his own funds to acquire it. Accordingly, respondent contends, petitioner has failed to prove his basis in the property or his entitlement to the depreciation claimed. To show entitlement to a deduction for depreciation, petitioner must establish, among other things, the depreciable basis of the property. See Delsanter v. Commissioner, 28 T.C. 845, 863 (1957), affd. in part, revd. and remanded on another issue 267 F.2d 39 (6th Cir. 1959). The evidence in the record relating to basis in the Lincoln Avenue II property consists solely of petitioner’s self-serving statements, which we reject because they are uncertain, ambiguous, and uncorroborated. See Frierdich v. Commissioner, 925 F.2d at 185; Tokarski v. Commissioner, 87 T.C. at 77. Accordingly, petitioner has not established basis and may not deduct depreciation with respect to the Lincoln Avenue II property in 1988. We therefore sustain respondent’s determination.Page: Previous 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 Next
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