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Background
These cases were submitted fully stipulated under Rule 122,
and the stipulated facts are so found.
At the time the petitions were filed, petitioners resided in
the following locations:
Petitioners Location
David Hutchinson Ketchum, Idaho
Isaac Kalisvaart and Francien Kalisvaart-ValkPortland, Oregon
William and Sharon Criswell Wellington, Florida
Robert and Judeen Bobosky Portland, Oregon
On June 21, 1993, petitioners formed Valley Ranch, Inc.
(VRI) as an Idaho corporation, and petitioners elected to have
VRI taxed pursuant to subchapter S of the Internal Revenue Code.
Petitioners constitute all of the shareholders of VRI.
On December 1, 1993, VRI entered into an option to purchase
a 526-acre parcel of partially developed real estate near Sun
Valley, Idaho (the Property). Prior to December 1, 1993, the
sellers of the Property had begun development of the Property as
a golf course residential community.
Also on December 1, 1993, VRI entered into an agreement with
the sellers of the Property for VRI to continue to develop the
Property as follows:
Acreage Use
189 Acres 99 residential lots
162 Acres Hale Irwin designed golf course
175 Acres Roads and common areas
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Last modified: May 25, 2011