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For 1987, Osceola County assessed the values of the Grissom
Parcels as follows:
Parcel Number Assessed Value
Parcel 1 $12,500
Parcel 2 14,955
Parcel 3 11,228
Total Assessed Value 38,683
OPINION
The parties agree that $40,000 was realized on the sale of
parcel 1 in 1986, and that petitioner is responsible for any gain
from that sale. The issue that remains for decision is
petitioner’s basis in parcel 1. The adjusted basis for
determining gain from the sale of property, whenever acquired,
shall be the basis determined under section 1012 and adjusted as
provided in section 1016. Sec. 1011(a). Under section 1012, the
basis of property shall be the cost of such property. Under
section 1016(a)(1), the basis of property shall be adjusted for
expenditures, receipts, losses, or other items, properly
chargeable to capital account.
When a part of a larger property is sold, the cost or other
basis of the entire property shall be equitably apportioned among
the several parts, and the gain realized or loss sustained on the
part of the entire property sold is the difference between the
selling price and the cost or other basis allocated to that part.
Fasken v. Commissioner, 71 T.C. 650, 655 (1979); sec. 1.61-6(a),
Income Tax Regs. An equitable apportionment of cost basis may
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