David C. Hutchinson, et al. - Page 10




                                       - 10 -                                         
               VRI’s 1994 U.S. Income Tax Return for an S Corp. (Form                 
          1120S) was prepared using the alternative cost method under Rev.            
          Proc. 92-29, to allocate a ratable portion of the following total           
          actual and estimated costs to VRI’s cost bases in all of the                
          residential lots on the Property:                                           

          Total Actual and Estimated Costs and Expenses to be AllocatedAmount               
          VRI’s total actual acquisition costs for the Property  $ 5,715,345          
          VRI’s total estimated construction costs for the Golf Course13,390,624           
          VRI’s total estimated construction costs for the Clubhouse3,707,662            
          VRI’s total actual 1994 interest expense relating to both the               
          the Golf Course and the Clubhouse                      1,160,405            
          VRI’s total estimated post-1994 interest expense relating to                
          the Golf Course and the Clubhouse                      5,861,595            
          Total                                                  $29,835,631          

               On VRI’s 1994 Federal income tax return, in computing its              
          gain on the residential lots sold in 1994, VRI computed its cost            
          bases in the lots based on an allocation of the above total                 
          actual and estimated costs for the Golf Course and the Clubhouse,           
          thereby reducing VRI’s reported gain for 1994 with respect to the           
          lots sold.                                                                  
               During the transition period, on VRI’s 1996, 1997, 1998, and           
          1999 Federal income tax returns for an S Corp., VRI apparently              
          did not claim any depreciation deductions with respect to its               
          costs of constructing the Golf Course and the Clubhouse.                    
               In the statutory notice of deficiency, respondent treated              
          VRI’s development and sale of the residential lots on the                   
          Property as a project separate from VRI’s construction of both              
          the Golf Course and the Clubhouse, and therefore respondent                 





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