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concession that petitioners have satisfied the requirements of
section 7491(a)(2).
The stipulated joint exhibits and petitioners’ exhibits
contain detailed financial information, including total revenue
and expenses figures for Village West for the years in issue.
Petitioners rely primarily on the findings of the ad hoc
committee, of which Mr. Baker was a member, with certain
adjustments. AFVW management informed its AFVW residents that
certified data from the financial records of AFVW for the years
in issue was provided to the ad hoc committee and that the
committee coordinated and worked with management to review and
make recommendations regarding the allowable deductions for
medical expense. This financial information and the ad hoc
committee’s report are detailed and contain the revenue and
expense figures necessary to calculate petitioners’ medical
deductions for the years in issue. After discussing this issue
with the parties at trial and examining their briefs, we
interpret petitioners’ position to be that both the ad hoc
committee’s findings and the findings resulting from petitioners’
subsequent adjustments are appropriate methods of calculating the
appropriate allocation percentage and determining petitioners’
medical deductions.
After thorough review and critical analysis of the
stipulated joint exhibits and petitioners’ exhibits, we find that
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