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Quijano v. United States

United States Court of Appeals for the First Circuit
93 F.3d 26 (1996)

Written by Nathan Benedict, JD

Facts

Carlos and Jean Quijano (plaintiffs) were US taxpayers who purchased a residence in the UK for £297,500, financed through a mortgage. They made £45,647 of capital improvements to the residence. The Quijanos sold the residence in 1990 for £453,374. In their 1990 tax return, they reported a $308,811 capital gain, using the date of purchase exchange rate ($1.49/pound) for the adjusted cost basis, but the date of sale exchange rate ($1.82/pound) for the sale price. The Quijanos later amended their return to claim a $30,610 refund, based on using the date of sale exchange rate for the adjusted cost basis, reducing the capital gain to $199,491. The Internal Revenue Service (IRS) (defendant) disallowed the amended return. The IRS argued that the total cost basis for the residence should be calculated using the exchange rate in effect when it was purchased and each capital improvement payment was made. Under this calculation, the Quijanos were entitled to a $2,668 refund. The district court entered judgment in this amount, and the Quijanos appealed.

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Holding and Reasoning (Cyr, J.)

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