Brian E. & Marcie L. Mallin - Page 8




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          the $203,000 sale price for the South Dakota property between the           
          residence and the workshop.                                                 
               Respondent urges us to apportion the sale proceeds of the              
          South Dakota property by square footage; because the workshop was           
          approximately 9 percent of the home’s overall square footage,               
          respondent suggests that we should allocate 9 percent of the                
          home’s sale price to the workshop.  However, given that workshop            
          space is not as valuable as living space in a home, we decline to           
          use respondent’s calculation method.                                        
               Petitioners, on the other hand, urge us to assign $4,000 of            
          the sale price to the workshop.  They arrive at this number by              
          calculating the difference between the 1998 appraisal of $199,000           
          and the 2001 sale price of $203,000; in other words, petitioners            
          attribute the entire increase in the home’s value between 1998              
          and 2001 to the workshop.  They contend that all of the increase            
          must have been a result of the workshop as that was the only                
          thing that changed in the period between appraisals.  We disagree           
          with petitioners’ argument.                                                 
               Rather than use either of the parties’ methods to allocate             
          the proceeds from the sale of the South Dakota property between             
          the residence and the workshop, we shall use the only allocation            
          approach supported by the record; i.e., taking the average of the           
          appraisals of the workshop value used for the 2001 sale.  This              
          approach may be an imperfect solution given the fact that the               







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