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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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