Peter T. Storaasli - Page 17

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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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