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progress, with the following description "Beaumont Subdivision
(Tract 10018) 46 unimproved lots." In regard to the 14 lots in
Tract No. 10018-1, the lots were recorded in work-in-
progress/construction-in-progress account and finished houses
account. Petitioner never moved the property from these
accounts. Petitioner also listed the Exchange Property, Tract
No. 22332, under the category of work-in-progress/construction-
in-progress (Account No. 1160), and never moved the Exchange
Property from that account during the period of 1978 to 1989.
Petitioner asserts that the characterization of the Exchange
Property as work-in-progress was made by its accountants without
Mr. Baker's knowledge. Mr. Baker claims that the accountants
incorrectly classified properties under work-in-progress
accounts. Petitioner points out that many properties that were
clearly held for investment (such as fast-food stores) were
listed under the work-in-progress category. It attempts to
categorize the work-in-progress category as a suspense account
used to keep track of expenses. Petitioner concludes that the
Exchange Property was listed under the work-in-progress account
because the petitioner made expenditures for engineering costs
associated with the property.
In its assertions that properties were listed
inconsistently, petitioner solely relies on Mr. Baker's
statements about its use of the properties and the
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