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feet � 12,700 total square feet) and the remaining 87 percent to
ATV for business use.
Neither party addressed ATV’s payment of rent for the use of
the parking area and driveway beside and behind the main house.
There is no record evidence of the square footage of the parking
area and driveway. Unless ATV employees carpooled to work in
1997, it is fair to assume all or almost all of the employees
drove their own cars to work, requiring at least 20 parking
spaces plus the reserved spot for Mr. Cutts. Under section
132(f)(2)(B), the dollar limit for qualified parking was $165 in
1996 and $170 in 1997. See Rev. Proc. 95-53, sec. 3.06, 1995-2
C.B. 445, 448; Rev. Proc. 96-59, sec. 3.07, 1996-2 C.B. 392, 395.
In absence of record evidence of the going monthly rate
during 1997 for outdoor parking spaces or for an outdoor parking
lot for 21 cars in Mobile, Alabama, we estimate, bearing heavily
against petitioners, whose inexactitude is of their own making,
the fair market rent for the parking area and driveway at
Landmark Hall. See Cohan v. Commissioner, supra. Using the
qualified parking limits under section 132(f)(2)(B), and taking
account of the lower cost of living in Mobile, Alabama,4 and the
likelihood that the rent a landowner would charge a parking lot
4For the fourth quarter of 1997, Mobile, Ala., had a cost-
of-living index of 93.6, which is 6.4 points below the national
average of 100. See Low Cost Living in Mobile, The View--A
Monthly Business Publication for the Members of the Mobile Area
Chamber of Commerce, Vol. XXX, No. 5 at 2 (May 1998).
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