Peter T. Storaasli - Page 8

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          adjustments for the remaining expenses for lack of                          
          substantiation.                                                             
          Hollywood Hill Lot                                                          
               In April 1996, petitioner purchased two adjacent parcels of            
          real property, one of which had a home situated on it, for                  
          $732,500.9  Petitioner and his spouse resided in the home,                  
          located at 16109 167th Avenue Northeast, Woodinville, Washington,           
          after selling the Rose Point Lane property.  Petitioner improved            
          the empty lot adjacent to the home, the Hollywood Hill lot, by              
          constructing a fence around the property.  In October 1999,                 
          petitioner sold the Hollywood Hill lot for $235,000.                        
               Respondent concluded that petitioner’s cost basis in the               
          Hollywood Hill lot was $185,000, approximately 25 percent of the            
          total purchase price of both lots.10  Respondent added to                   
          petitioner’s cost basis $431, which represented 25 percent of the           
          costs incurred in the purchase of both lots, and $5,974 for the             
          cost of constructing a fence on the Hollywood Hill lot.  In                 
          computing the amount realized on the sale, respondent subtracted            
          $9,957 from the sale price to account for selling costs.  Using             


               9The cost of purchasing the residence, taking into account             
          $1,294 of acquisition costs, was $548,794.                                  
               10The parties stipulated that respondent had determined that           
          petitioner’s basis in the Hollywood Hill lot was $185,000 and               
          that it was 25 percent of the combined purchase price of the two            
          adjacent lots.  In fact, the amount respondent allowed as basis             
          is 25.26 percent of the combined purchase price.                            





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