Steven K. Stoddard and Ellen M. Stoddard - Page 20




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               As we understand petitioners’ position, they contend that              
          they expended $20,796 on improvements to the condo and that the             
          cost of those improvements, when added to their cost basis in the           
          condo of $165,000, results in their having an adjusted basis in             
          the condo of $185,796, which is the amount of petitioners’ basis            
          that they reported in Schedule D of their 1995 joint return.12              
          The parties stipulated that petitioners’ adjusted basis in the              
          condo must reflect a reduction of at least $5,491 for the depre-            
          ciation that petitioners claimed in Schedule E of their 1995                
          joint return.  Consequently, according to petitioners, their                
          adjusted basis in the condo at the time of its sale was $180,305            
          (i.e., basis of $185,796 reported in Schedule D of petitioners’             
          1995 joint return reduced by depreciation of $5,491 for 1995 that           
          the parties stipulated should reduce petitioners’ basis).  It is            
          respondent’s position that at the time of the sale of the condo             
          in 1995 petitioners’ adjusted basis in the condo was $148,527.              
          In support of that position, respondent contends (1) that peti-             
          tioners have failed to establish that they made the improvements            
          to the condo that they are claiming and (2) that petitioners’               
          adjusted basis in the condo should be calculated by reducing                


               12Ms. Stoddard did not specify at trial or on brief the                
          exact amount that petitioners are claiming they incurred for                
          improvements to the condo.  The checks on which petitioners rely            
          to support their position with respect to the claimed improve-              
          ments to the condo total $13,983.45.  However, we assume that the           
          amount of such claimed improvements is equal to the excess (i.e.,           
          $20,796) of the adjusted basis of $185,796 that petitioners                 
          claimed in Schedule D of their 1995 joint return over their cost            
          basis in the condo of $165,000 to which the parties stipulated.             




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