Florida Country Clubs, Inc. - Page 3

                                        - 3 -                                         
          reasons explained below, we find that petitioners are not                   
          entitled to administrative costs.                                           
                                     Background                                       
               Petitioners are James R. Mikes (Mikes), Deborah A. Hamilton            
          (Hamilton), Florida Country Clubs, Inc. (FCC), and Suncoast                 
          Country Clubs, Inc. (SCC).  FCC and SCC are corporations that               
          elected to be taxed under subchapter S for 1993, 1994, and 1995.            
          Mikes and Hamilton were married and filed joint returns for those           
          years, and they were shareholders of the corporations.2                     
               Respondent commenced an audit of FCC for the years 1993 and            
          1994 in December 1995, to examine, inter alia, certain claimed              
          depreciation expenses and a possible understatement of gross                
          receipts.  In 1996 respondent expanded the audit for those years            
          to include Mikes, Hamilton, and SCC.  The audit encompassed, in             
          addition to the depreciation deductions, the deductibility of net           
          operating losses as well as interest income and expenses claimed            
          by petitioners on account of certain loans.  In May 1999, the               
          audit was further widened to include the year 1995 for all                  
          petitioners.                                                                
               On September 23, 1997, respondent sent petitioner FCC a 30-            
          day letter proposing to increase the income reported on its 1993            
          and 1994 returns in the amounts of $1,168,554 and $44,219,                  

               2 At the time the petition was filed, petitioners Hamilton             
          and Mikes resided in Florida and the principal place of business            
          of the corporate petitioners, FCC and SCC, was also in Florida.             





Page:  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