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Petitioner made no effort whatsoever at trial to prove the
existence or amount of the expenses he argues should be added to
each property’s adjusted basis.14 In the absence of any
corroborating evidence, we are not required to accept
petitioner’s self-serving testimony. Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). Further, the failure to produce evidence,
in support of an issue of fact as to which a party has the burden
of proof and which has not been conceded by such party’s
adversary, may be a ground for deciding the issue against that
party. Rule 149(b).
In addition, petitioner cites no authority to support his
position that the expenses he allegedly incurred for landscaping,
routine maintenance and repairs, utilities, and insurance, with
respect to either the Rose Point Lane property or Hollywood Hill
lot, may be added to the adjusted basis of either property.
Petitioner did not prove that these expenses were for permanent
improvements that have a useful life or that they increased the
value of the property substantially beyond the taxable years in
question. Secs. 263, 1016; secs. 1.263(a)-1 and -2, 1.1016-2,
Income Tax Regs. Consequently, there is no basis for concluding
that the expenses claimed by petitioner were capital expenditures
14Petitioner did not allege alternatively or prove that any
of the expenses in question were business expenses deductible
under sec. 162.
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