- 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 respondentPage: 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