- 29 - Miles, as trustee, sold Lots 6 through 30, for $540,000.18 The purchasers paid $89,077 in 1988 and issued a purchase money mortgage for the remainder. We are unable to locate this payment on petitioner’s spreadsheets for 1988, and it does not appear that he reported any amount of this payment as income on his return for 1988. OPINION In computing petitioner’s gains from the sales in 1985, 1986, and 1988, respondent apportioned the cost basis of the entire property equally among Lots 1 through 30 and Tract A, and assigned a basis of $1,903 to each lot and tract.19 Respondent determined that petitioner realized a gain of $20,097 from the sale in 1985,20 a gain of $21,097 from the sale to Mr. Dugger in 1986,21 and installment gains of $77,298 from the sales in 1988.22 On brief, petitioner does not address the disputed gains 18Petitioner incurred selling expenses of $23,831 for this sale. 19Cost basis for each lot and tract ($1,903) = cost of the entire property ($59,005)/the number of lots and the tract (31). 20Gain realized ($20,097) = amount realized ($22,000) - adjusted basis ($1,903). 21Gain realized ($21,097) = amount realized ($23,000) - adjusted basis ($1,903). 22Gross Profit ($468,594) = sales price ($540,000) - selling expenses ($23,831) - total of the adjusted bases in lots 6-30 ($47,575); gross profit percentage (0.867767) = gross profit ($468,594)/ contract price ($540,000); installment gain from sale in 1988 ($77,298) = payments received in 1988 ($89,077) x gross profit percentage (0.867767).Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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