- 20 - petitioner’s methodology were reasonable, the invoices that petitioner proffered to substantiate the costs he claims to have incurred in connection with the construction of the later-built yachts were repeatedly shown to have dates that preceded the commencement of construction of the yacht whose costs they purportedly substantiated. Even more egregious were repeated instances where invoices’ dates had been crudely altered in an effort to make the invoices appear to have been created within the time period that the yacht whose costs they purported to substantiate was built. In sum, petitioner’s effort to invoke the Cohan rule to substantiate his claimed basis in the three yachts is wholly unreliable, and we reject it. Because petitioner has failed to substantiate any basis in the three yachts beyond that determined by respondent, we sustain respondent’s determination that petitioner had unreported gain from the sale of yachts of $155,848, $527,074, and $615,119 in 1994, 1996, and 1997, respectively. Gain From Sale of Real Property In 1995, petitioner sold real property at 6729 Westfield Boulevard, Indianapolis, that he leased to the Winston Yacht and Country Club, Inc. Petitioner reported an adjusted basis in the Westfield Boulevard property at the time of sale of $1,045,742, which included capital improvements of $232,400. RespondentPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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