- 2 -
OPINION
SWIFT, Judge: These cases were consolidated for trial,
briefing, and opinion. For 1994, respondent determined the
following deficiencies in petitioners’ Federal income tax:
Petitioners Deficiency
David C. Hutchinson $442,746
Isaac M. Kalisvaart and Francien Kalisvaart-Valk358,095
William T. and Sharon L. Criswell 188,862
Robert S. and Judeen M. Bobosky 128,054
The issues for decision involve whether, under the
alternative cost method of Rev. Proc. 92-29, 1992-1 C.B. 748
(Rev. Proc. 92-29), a real estate developer, in calculating gain
on the sale of residential lots sold in 1994, may allocate to the
developer’s bases in the lots sold estimated construction costs
relating to certain common improvements to the development and
whether the developer may include, in the calculation of
estimated construction costs, estimated, future-period interest
expense relating to the common improvements.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1994, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Page: Previous 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