106 T.C. No. 12 UNITED STATES TAX COURT HIGHLAND FARMS, INC. AND SUBSIDIARY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 6642-93. Filed April 17, 1996. P, an accrual basis taxpayer, operates a continuing-care residential retirement community that has five types of accommodations: cluster homes or condominiums; apartments; a lodge; a rest home; and a skilled nursing health-care center. The rest home and health-care center are not involved in this case. The residents purchase the cluster homes or condominiums for the full purchase price and pay the taxes, insurance, and utilities for their unit. The cluster home or condominium owner can transfer the unit only to P which must repurchase the unit at certain percentages of the original purchase price during the first 7 years after purchase and thereafter at not less than 76 percent of the original purchase price. The residents of the apartments and the lodge must pay a lump-sum entry fee before taking occupancy and must thereafter pay a monthly rent. Except for the first 10 percent, the entry fees for the apartments are refundable on a prescribed percentage basis over a 5-year period. Except for the first 5 percent, the entry fees for the lodge are refundable on a prescribed percentage basis over a 20-year period.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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