- 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
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