- 2 - indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Petitioners are cash basis taxpayers who resided in Knoxville, Iowa, at the time that they filed their petition. On April 10, 1978, petitioner purchased a remainder interest in 80 acres of land in Poweshiek County, Iowa, for $20,000. At the time of purchase and at least through 1997, petitioner’s sister held a life estate in the 80 acres. Petitioner held the remainder interest with his three sons as tenants in common, each owning a one-fourth interest in the property with an adjusted basis of $5,000. The transaction was entered into for profit. The 80 acres involved was made up of two 40-acre tracts of land. The two 40-acre tracts were approximately equal in value. Located on one of the 40-acre tracts was a well-preserved barn that was considered a showplace. The value of the barn was approximately 54 percent of the total value of the 40-acre tract upon which it stood. The barn was used for agricultural purposes, and the remainder of the land was used for pasture by a third party. In 1997, a windstorm or tornado swept through the area where the property is located and destroyed the barn. All that remained was approximately $2,000 worth of salvageable lumber.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011