Woody F. Lemons - Page 26

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             loss.  However, in computing the long-term capital loss,                 
             it appears that respondent treated petitioner as having a                
             basis of $1,120,000 in the eight memberships, or $140,000                
             per membership, rather than a basis of $1,240,000, or                    
             $155,000 per membership.                                                 
             Annual Dues Issue                                                        
                  At the time petitioner purchased 9 of the 18 unsold                 
             class A memberships in the club, he signed membership                    
             documents identical to those signed by the other members.                
             He thereby obligated himself to pay the annual dues                      
             attributable to each membership.  As described by the                    
             promotional booklet issued to prospective purchasers,                    
             the dues covered various expenses, including insurance,                  
             staff services, such as the manager's salary, and                        
             maintenance costs incurred in running the club.  According               
             to the booklet, the dues were estimated to be approximately              
             $4,000 for the first year.  Based upon the eight class A                 
             memberships that petitioner held during 1986, it would                   
             appear that he was liable to pay $32,000 in dues during                  
             the year.                                                                
                  On the Schedules E, Supplemental Income Schedule,                   
             that are attached to petitioners' 1986 income tax                        
             returns, each petitioner claims a deduction of $5,250                    
             for "management fees" attributable to the beach club.                    






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