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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.
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