Trinity Meadows Raceway, Inc., Jack M. Lenavitt, A Person Other Than The Tax Matters Person - Page 2

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          S corporation administrative adjustment, stating, with respect to           
          1991, that respondent had increased Trinity's ordinary income by            
          $233,661 and disallowed its $2,028,750 casualty loss in full.               
          Following petitioner's concession of the correctness of                     
          respondent's adjustment to Trinity's ordinary income, we must               
          decide whether Trinity may deduct the casualty loss.  We hold it            
          may not.  Unless otherwise stated, section references are to the            
          Internal Revenue Code in effect for the year in issue.  Rule                
          references are to the Tax Court Rules of Practice and Procedure.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  The stipulated                
          facts and the exhibits submitted therewith are incorporated                 
          herein by this reference.  Trinity was incorporated in 1988 and             
          elected subchapter S status as of January 1, 1989.  It filed a              
          1991 Form 1120S, U.S. Income Tax Return for an S Corporation, on            
          September 15, 1992.  At all times relevant herein, its principal            
          place of business was on property (the Property) located at 130             
          Trinity Meadows Lane, Willow Park, Texas.  The Property consists            
          of four tracts of land measuring 99.916 acres, 33.597 acres, .6             
          acres, and 69.391 acres, respectively.  Two rivers run along or             
          through the Property's borders.                                             
               Trinity's original shareholders purchased the Property on              
          March 6, 1987, intending to develop it for parimutuel racing,               
          which would later be legalized in the State of Texas.  At the               





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