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The cost basis of each property at issue; (2) the costs he
incurred to purchase, refinance, and sell the properties; and (3)
the expenditures he incurred for improvements he made to certain
of the properties. Petitioner, however, did not provide the
Appeals officer with any documentation to substantiate any of the
other expenses petitioner claimed with respect to the properties
at issue. After reviewing the information provided by
petitioner, respondent recomputed petitioner’s income tax
deficiencies for 1996, 1998, and 1999. The pertinent facts
regarding petitioner’s ownership of each property, and
respondent’s revised position with respect to each property’s
adjusted basis and the gain petitioner recognized on each sale,
are set forth below.4
Market Street Property
In June 1992, petitioner purchased the Market Street
property for $143,500. The Market Street property was a single-
4In addition to the three properties petitioner sold in 1996
and 1999, in October 1998, petitioner sold his interest in a
time-share condominium for $12,500. The time-share condominium
was located at L-16-C Ellowee, Manson, Washington (hereinafter,
the Ellowee Time-share), and petitioner had purchased it in
August 1992, for $19,750. After taking into account acquisition
and disposition costs, respondent determined that petitioner
sustained a loss of $9,892 on the sale of the Ellowee Time-share.
Because respondent conceded that there is no deficiency in 1998,
and petitioner did not dispute respondent’s determination with
respect to the Ellowee Time-share property in his petition or
trial memorandum or advance any arguments regarding the Ellowee
Time-share at trial, we do not decide any issues relating to
petitioner’s 1998 taxable year. See Rule 34(b)(4).
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