Lee F. McClune and Harriet R. McClune - Page 2

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          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.              






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