Date: October 25, 2012
From: Sladjana Vasic
To: Professor Raymond Placid
Re: AmeriSouth XXXII, LTD., et al. v. Commissioner, 67 T.C. Memo. (2012)
FACTS
AmeriSouth XXXII, Ltd. acquired the Garden House Apartments in Mesquite, Texas in 2003 for $10.25 million. According to its owner, Ruel Hamilton, AmeriSouth is a general partner in about 50 partnerships, and AmeriSouth Texas established AmeriSouth XXXII in 2003 to buy the aforementioned complex. The complex was constructed in 1970, sits on over 16 acres of land with more than 40 buildings. Mr. Hamilton also owns AmeriSouth Management, L.P., which is responsible for the maintenance of a portion of the complexes.
Roughly 70 of the 366 units are fully furnished. Even those units
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AmeriSouth argued that cost-segregation study allocates $65,381 of Garden House's depreciable basis to “site preparation and earthwork,” depreciable over 15 years as a land improvement is allowable because it is a “site development,” but nowhere does it describe what work is included in this category. On the other hand, the Commissioner's expert claims that work papers show the expenses relate to the initial clearing and grubbing (i.e., tree removal) of the land which occurred before the apartments' construction in 1970.
Furthermore, the Commissioner states that clearing and grubbing are not depreciable because they are not subject to wear and tear and generally make the land more valuable. Reg §1.167(a)-2. “Tangible property states the depreciation allowance in the case of tangible property applies only to that part of the property which is subject to wear and tear, to decay or decline from natural causes, to exhaustion, and to obsolescence. The allowance does not apply to inventories or stock in trade, or to land apart from the improvements
Masked behind the aging oak trees covered in moss, and past the emerald waters of the panhandle, stands a white mansion that reveals the history of the local of Point Washington area. A large, white, almost plantation-style home is the focal point of Eden Gardens State Park, and a symbol of the legacy of the family. Large centuries-old oak trees embellish the land surrounding the house, making it a pivotal icon of the nature left untouched. The house itself contains hundreds of years of memories, and the land that occupies the area encompasses an even larger spectrum of Florida history. Once the site of a family lumber mill business in the late 1880’s, today it stands unnoticed as a legacy in the South Walton area of Florida.
The agreement did not include any personal property, but it did cover: " All buildings, plumbing, heating, lighting fixtures, storm sash, shades, blinds, awnings, shrubbery, and plants". The purchasers took possession on June 14, 1946, and discovered that certain articles which had been on the premises at the
The pool cost the petitioner over $19,000, and we cannot accept his contention that such amount was spent primarily for therapy for his leg in view of the limited need for such therapy and the alternatives which were then available.
Parent Corporation owns 85% of the common stock and 100% of the preferred stock of Subsidiary Corporation. The common stock and preferred stock have adjusted bases of $500,000 and $200,000, respectively, to Parent. Subsidiary adopts a plan of liquidation on July 3 of the current year, when its assets have a $1 million FMV. Liabilities on that date amount to $850,000. On November 9, Subsidiary pays off its creditors and distributes $150,000 to Parent with respect to its preferred stock. No cash remain to be aid to Parent with respect to the remaining $50,000 of its liquidation preference for the preferred stock, or with respect to any common stock. In each of Subsidiary’s tax years, less than %10 of its gross
Ann paid $500 for her books and supplies and she incurred living expenses of $7,400.
835-20-15-8 Land that is not undergoing activities necessary to get it ready for its intended use is not a qualifying asset. If activities are undertaken for the purpose of developing land for a particular use, the expenditures to acquire the land qualify for interest capitalization while those activities are in progress. The interest cost capitalized on those expenditures is a cost of acquiring the asset that results from those activities. If the resulting asset is a structure, such as a plant or a shopping center, interest capitalized on the land expenditures is part of the acquisition cost of the structure. If the resulting asset is developed land, such as land that is to be sold as developed lots, interest capitalized on the land expenditures is part of the acquisition cost of the developed land.
A 1099 is an important document that must be considered when a company employees independent contractors throughout the year. This form is similar to a W2, which reports wages earned by an employee. However, this is the form that is used for contractors that are not employed by the employee and who had more than $600 in payments from the company over the course of the year.
While Cove Creek Condominium Association v Vistal Land & Home Development, L.L.C., et al., Oakland County Circuit Court Case No. 16-155706-CH (Order Granting Summary Disposition, Dated February 10, 2017) is only a circuit court opinion, it certainly provides a significant amount guidance in interpreting MCL 559.167. Until there is a published court of appeals opinion that interprets MCL 559.167, attorneys, co-owners, condominium associations, developers, successor developers and title companies should be aware of the following takeaways from the Cove Creek case:
The subject is a one story house built in 1952 in the Southern Knoll Farms subdivision in Clifton. It is brick exterior, Good grade home sited on 5.1406 acre lot.
Facts: Murray Taxpayer was previously employed by a company who was illegally dumping chemicals into a river. Murray had knowledge concerning these illegal activities of his employer and made an ethical decision to report this to the Environmental Protection Agency. Upon inspection, the Environmental Protection Agency determined that Murrays employer was in fact illegally dumping and was appropriately fined for the charges. Murray’s employer reacted to his whistleblowing by firing him and making deliberate efforts to prevent Murray from gaining employment elsewhere. Murray then sued his former employer for damaging
1. All distributions (excluding reasonable salary) to Paula and Mary will be taxed as dividends to them. And the corporation could not deduct this part of distribution.
In this composition, we will be discussing two topics that go hand in hand when it is dealt with in tax accounting. To fully understand the scope of this article, passive activity is defined by the IRS as “any rental activity or any business in which the taxpayer gains income but does not materially participate in the activity”(IRS). Examples of passive activities can include equipment leasing and real estate leasing, in contrast to salaries, wages which are generally considered non-passive activities. As the article “Skip the dorm, buy your kid a condo” states, there are tax benefits when renting a property, but now individuals have exploited loopholes in the tax code that can be controversial and even illegal.
As a new employee in the financial reporting unit the task is to evaluate the relevant disclosures of the company’s latest annual report in accordance to the Income Tax requirements as per AASB 112.
Not by describing the details of the destruction of the acreage but the worth that it will be after the fact. Making sure that the town and council understands that the land is not being uprooted for any demeaning nature but for growth and opportunity that the town of Beatty is in great need, and if this opportunity is not met in a quick manner, the fact of the matter is that there will not be a need for land preservation for tourism because the land itself will not have any tourist. The town of Beatty is really relying on the jobs that this addition is going to bring and the revenue that will be put back into the state is in great need.