122 T.C. No. 8
UNITED STATES TAX COURT
DELBERT L. AND MARGARET J. BAKER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 448-02. Filed February 19, 2004.
Ps and AFVW executed a residence agreement
entitling Ps to lifetime residence at VW. VW provides
four different levels of accommodations. During the
years in issue, Ps resided in an independent living
accommodation which provides the lowest level of care
and resembles a regular residence that can be found in
any nonretirement living community. Ps paid monthly
service fees of $2,170 and $2,254 for 1997 and 1998,
respectively. Several amenities were available to Ps,
including medical services and the use of pool, spa,
and exercise facilities.
D, the vice president of finance for AFVW, the
operator of VW, calculated the portions of the monthly
service fees paid by independent living residents that
were allocable to medical care. C, an ad hoc
committee, of which P-H was a member, reviewed D’s
calculations. On the basis of certified financial
information provided by AFVW, C calculated a higher
amount allocable to medical care. Both D and C used
the percentage method to calculate the portions
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011