- 11 - disallowed VRI’s allocation, under the alternative cost method, of the total estimated costs of constructing the Golf Course and the Clubhouse to VRI’s cost bases in the residential lots sold in 1994. Shortly before trial herein was scheduled to take place, however, respondent abandoned his contention that the Golf Course and the Clubhouse constituted projects separate from VRI’s development and sale of the residential lots. Respondent acknowledged that the Golf Course and the Clubhouse constituted a single project integrated with VRI’s development and sale of improved residential lots. Respondent acknowledged that VRI could allocate under the alternative cost method the estimated costs of constructing the Golf Course to the lots sold. Respondent, however, for the first time in a pretrial brief contended that VRI had retained an ownership interest in the Clubhouse in 1994 and through the transition period, and therefore that the estimated construction costs of the Clubhouse would have been recoverable to VRI through depreciation and did not qualify under the alternative cost method for allocation by VRI to the lots sold in 1994 and in subsequent years. More specifically, with respect to VRI’s $13,390,624 in total estimated construction costs of the Golf Course (all of which related to nondepreciable improvements to the Property), respondent acknowledged that those estimated costs qualifiedPage: 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