David C. Hutchinson v. Commissioner

116 T.C. No. 14

UNITED STATES TAX COURT DAVID C. HUTCHINSON, ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 15912-98, 15958-98, Filed March 14, 2001. 15959-98, 15960-98. Held: Under the alternative cost method of Rev. Proc. 92-29, 1992- 1 C.B. 748, a real estate developer may allocate to its bases in lots sold $3,707,662 in estimated construction costs relating to common improvements. Held, further, $5,861,595 in estimated, future- period interest expense relating to common improvements does not qualify under the alternative cost method for allocation to the…