NHUSS Trust, et al. - Page 4

                                        - 4 -                                         
               The above improvement costs claimed by petitioners are                 
          reflected either in various building permits obtained by                    
          petitioners (Appendix A), in other contemporaneous records                  
          maintained by petitioners (Appendix B), or in petitioners’                  
          testimony at trial (Appendix C).2  The $56,284 in improvement               
          costs that respondent has allowed are based on the costs that are           
          reflected in the building permits (Appendix A) and on some but              
          not all of the costs reflected in the contemporaneous records               
          (Appendix B).  Also, a few additional costs that respondent has             
          allowed are reflected in Appendix D.  Respondent has disallowed             
          all of the costs reflected in Appendix C.                                   
               Further, in connection with the sale of their residence,               
          petitioners incurred closing costs of $61,864.                              
               In summary, petitioners and respondent calculate                       
          petitioners’ cost basis in the residence as follows:                        

                                           Calculation of                             
                                           Cost Basis in Residence                    
                                           Petitioners    Respondent                  
                 Purchase price            $ 45,000       $ 45,000                    
                 Improvements              286,070        56,284                      
                 Closing costs              61,864         61,864                     
                           Total           $392,934       $162,968                    






               2  For purposes of the above schedule, where the various               
          sources of evidence in the case reflect different amounts for the           
          same improvement, the schedule reflects the higher amounts.                 




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011