- 54 - reflect the relative fair market values of the portions of the larger property at the time of their purchase. Sec. 1.61-6(a), Example (2), Income Tax Regs. Our determination of the allocation of basis is a question of fact. Sleiman v. Commissioner, 187 F.3d 1352, 1360 (11th Cir. 1999), affg. T.C. Memo. 1997-530. Respondent relies upon the assessed values of the Grissom Parcels in 1987 to determine the relative values of those parcels when they were purchased in 1985. Respondent allocated the purchase price of $47,000 in 1985 to the parcels as follows: Percentage Parcel Assessed of Total Basis Number Value Assessed Value Allocated1 Parcel 1 $12,500 32% $15,040 Parcel 2 14,955 39 18,330 Parcel 3 11,228 29 13,630 Totals 38,683 100 47,000 1The basis allocated equals the purchase price multiplied by the percentage of the total assessed value of the parcels. After accounting for selling expenses of $4,458, respondent determined that petitioner realized a gain of $20,502.33 Petitioner contends that the methodology used by respondent to allocate cost basis to the Grissom Parcels is arbitrary. Petitioner argues that the cost basis should have been allocated according to the relative fair market values of the parcels in 33Gain ($20,502) = sales price ($40,000) - selling expenses ($4,458) - basis ($15,040).Page: Previous 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 Next
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