NHUSS Trust, et al. - Page 16

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                       Residence Cost Basis           Amount                          
                       Purchase price                 $ 45,000                        
                       Improvements                                                   
                       Residence                      28,000                          
                       Swimming pool                  31,190                          
                       Second story addition          16,665                          
                       Interior remodeling            1,022                           
                       Exterior                       3,527                           
                       Alarm                          825                             
                       Closing costs                  61,864                          
                                    Total             $188,903                        

               We calculate petitioners’ taxable gain on the sale of the              
          residence in 2000 to be $101,907 ($790,000 sale price, less                 
          $188,903 cost basis, less $500,000 exemption, equals $101,907               
          capital gain).                                                              

          Charitable Deduction for Value of Van                                       
               Generally, under section 170(a)(1), a deduction is allowed             
          for charitable contributions made within the year.  See sec.                
          1.170A-1, Income Tax Regs.  The regulations state that the amount           
          to be allowed for a charitable contribution of property other               
          than money is to be the “fair market value of the property at the           
          time of the contribution”.  Sec. 1.170A-1(c)(1), Income Tax Regs.           
               Generally, the best evidence of fair market value is an                
          actual sale of the property in an arm’s-length transaction within           
          a reasonable time before or after the valuation date.  Berry                










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