- 57 -
$23,500,36 should be allocated to the parcel sold in 1986 and
that he is responsible for $12,042 of gain.37
Petitioner is not a disinterested witness. Further, his
opinion regarding the value of the Grissom Parcels is based on
his own subjective viewpoint about the desirability of those
individual parcels. Petitioner presents no objective analysis to
support his valuation of parcel 1 to be “at least half of the
entire purchase”. Petitioner presented no records that were
prepared at the time of the purchase or sale that reflected the
allocation in his testimony, and he completely failed to report
the sale on his income tax return. We cannot accept petitioner’s
testimony to establish the relative values of the Grissom
Parcels, and he has failed to overcome the presumption of
correctness that attaches to respondent’s determination. We hold
that petitioner’s basis in parcel 1 was $15,040 and that his gain
from its sale in 1986 was $20,502.
36Petitioner testified:
Q And what value do you place as to the basis when
you bought it--of the total purchase price, what value
do you attribute to the value of parcel 1?
A I had figured that it was worth at least half of
the entire purchase, which would mean that it was
equivalent to the other two parcels put together.
37Gain realized ($12,042) = amount realized ($40,000) -
selling expenses ($4,458) - basis ($23,500).
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