- 7 - amount realized on the sale, respondent subtracted $60,516 from the sale price to account for selling costs. Using an adjusted sale price of $1,004,484 and an adjusted basis of $433,066, respondent concluded that petitioner must recognize gain of $571,418 on the sale of the Rose Point Lane property. Respondent did not include any of the following expenses, which petitioner claims should increase the adjusted basis of the Rose Point Lane property, in computing petitioner’s gain:8 Item Cost Landscaping and repairs $21,750 Maintenance for 100 mos. at $150/mo. 15,000 Refinancing expenses (three times) 26,500 Mortgage interest 325,100 Insurance for 100 mos. 11,150 Property taxes for 100 mos. 104,167 Personal labor of 1500 hrs. at $20/hr. 30,000 Settlement charges for utilities 200 Respondent concluded that the costs petitioner allegedly incurred for landscaping and repairs, maintenance, utilities, and personal labor did not constitute capital improvements that must be added to the property’s basis. Respondent disallowed any basis 7(...continued) costs and adjusted the sale price downward by $11,333 to account for disposition costs. 8In the petition, petitioner claimed he incurred improvement expenses of $75,000, but he did not argue in his trial memorandum, at trial, or in his posttrial memoranda that he was entitled to any deductions or basis adjustments for improvements. Petitioner also failed to produce any evidence on this point at trial. We conclude, therefore, that petitioner has abandoned this argument. See Leahy v. Commissioner, 87 T.C. 56, 73-74 (1986).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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