Peter T. Storaasli - Page 18

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          that may be added to the adjusted basis of either property and              
          recovered upon sale.                                                        
               With respect to petitioner’s argument that the cost of his             
          personal labor should increase his adjusted basis in the                    
          properties at issue, no provision of the Code authorizes an                 
          increase in basis for the cost of a taxpayer’s personal labor,              
          and we have consistently held that the cost of a taxpayer’s                 
          personal labor shall not be considered in computing adjusted                
          basis, regardless of whether the property is held for the                   
          production of income or as a principal residence.  Cox v.                   
          Commissioner, T.C. Memo. 1982-667; Bayly v. Commissioner, T.C.              
          Memo. 1981-549; Erwin v. Commissioner, T.C. Memo. 1978-10; Miller           
          v. Commissioner, T.C. Memo. 1975-8.  Consequently, we reject                
          petitioner’s argument.                                                      
               D.   Basis Adjustment Under Section 1034                               
               Respondent concluded that petitioner must recognize gain of            
          $571,418 on the sale of the Rose Point Lane property.  In                   
          arriving at that figure, respondent adjusted petitioner’s cost              
          basis in the Rose Point Lane property to account for acquisition            
          and refinancing costs and deferred gain from the sale of                    
          petitioner’s previous residence, and adjusted the sales price to            
          account for the cost of selling the property.  Because petitioner           
          reinvested a portion of the sale proceeds from the Rose Point               
          Lane property in a new residence, however, petitioner must                  






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