FRGC Investment, LLC, James P. Mehen, Tax Matters Partner - Page 8




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          1999 plan, but rejected the golf course placement in the middle             
          of the dry lake area.  In December 1999, a new general                      
          development plan report (December 1999 plan) was presented to the           
          Coconino County Board that encompassed a land swap with Bob                 
          Simple (Simple), who owned land adjacent to the subject property.           
          Simple traded 250 acres of his property for the dry lake caldera            
          and 36 acres of developable sites.  Simple then sold the dry lake           
          caldera to the Grand Canyon Trust, and it eventually became the             
          property of the Federal Government under control of the Coconino            
          National Forest.                                                            
          FRGC’s Partnership Returns                                                  
               On its 1997 Form 1065, U.S. Partnership Return of Income,              
          FRGC reported interest income of $14,095 and “other deductions”             
          of $669,126.  The claimed deductions consisted of the following:            
                    Management and supervision    $158,000                            
                    Marketing expense             104,851                             
                    Office and overhead           188,000                             
                    Course design                 23,620                              
                    Engineering                   61,435                              
                    Environmental fees            26,111                              
                    Hydrology                     2,582                               
                    Land planning fees            24,741                              
                    Zoning fees                   19,901                              
                    Travel                        2,758                               
                    Other fees and expenses       10,000                              
                    Land acquisition              8,103                               
                    Accounting fees               5,850                               
                    Planning fees                 31,372                              
                    Amortization expense          1,802                               
                    Total                         $669,126                            









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