Clovernook Country Club offers you a feast for the senses. Everyone. Private lessons are also available. The mere fact that a certified public accountant has prepared a tax return does not mean that he or she has opined on any or all of the items reported therein. Neonatology Assocs., P.A. Apr 2018 - Aug 20224 years 5 months. We AFFIRM. See also Reynolds v. Giuliani, 506 F.3d 183, 197 (2d Cir. Recent. Because the record here is complete and presents only uncontested facts, and those facts plainly permit only one conclusion, we may resolve this issue ourselves. Invalidating those deductions resulted in Losantiville having underpaid tax on its unrelated business income between 2010 and 2012. Saunders v. Comm'r, 75 F. App'x 494, 496 (6th Cir. (CCH) 947 (1989), aff'd, 922 F.2d 833 (3d Cir. Jay Hingsbergen, General Manager jay@losantivillecc.com Dylan Edwards, Controller dylan@losantivillecc.com Julia Whitney, Administrative Assistant & Communications Manager julia @losantivillecc.com 513-631-4133 Clubhouse: 513-631-4133: Fax: In Losantiville Country Club v.Commissioner, No. May 31 - Aug 22, 2022. For example, in Estate of Kluener, we noted that Kluener underpaid tax when he transferred several horses to his closely-held corporation, sold them, then impermissibly returned the tax-free proceeds to his personal accounts. FAQs About Us TSG site rules TSG Membership Options Contact Us. The LCC Swimming Pool is open & waiting for you to come over & cool off. Some can as little as $500 to join, while your premium country clubs can demand $500,000 or even more. The course plays longer than its posted length due to our rolling hills and doglegs that the golfer encounters. Golfer's amenities include: 2023 Losantiville Country Club. at 164 n.15, 110 S.Ct. As recently asJune 2010, there were 223 Met rounds played, with only 1 player breaking par for their round. Invalidating those deductions resulted in Losantiville having underpaid tax on its unrelated business income between 2010 and 2012. No matter what your decision, these clubs are all like adult camps. In September 2009, the Clubhouse of The Ridge Club was totally remodeled, re-opening in May, 2010. The club offers an 18-hole championship course and great practice facilities. Membership. station 19 fanfiction maya injured; morgan bay boats for sale; camden football fight; razer kraken v2 randomly disconnects; ark magmasaur fertilized egg spawn command; Data safety. You can explore additional available newsletters here. 1.183-1(a) (noting that [n]o inference is to be drawn from either Section 183 or its associated regulations that any activity of a corporation (other than an electing small business corporation) is or is not a business or engaged in for profit). The pool is open from 11am to 8pm, Tuesday through Sunday and closed on Mondays. Co. v. Comm'r, 444 F.3d 771, 777 (6th Cir. Pay only a cart fee when playing golf. This App allows LCC members to check your statement, view the roster and BOOK ONLINE TEE TIMES. We offerouting packages which include a variety of breakfast, lunch, and/or dinner options to go along with your great day on our beautiful golf course. Copyright 2023, Thomson Reuters. Western Hills Country Club is a proud supporter of the Evans Scholars program and has caddies available on both Saturdays and Sundays for rounds starting before 10:00AM. All Rights Reserved. Reg. Land appreciation: Similarly, Losantiville never demonstrated that it owns real estate primarily with the intent to profit from increase in its value, or that its nonmember events reduce[] the net cost of carrying the land for its appreciation in value. Treas. Losantiville Country Club v. Comm'r, 114 T.C.M. We estimate that the average price of a golf club membership (assuming customer type is a local individual) in Singapore in 2020 is about S$77,654, a S$10,231 increase from the year before. Some additional fees may apply for larger groups requiring supplementarycart rentals. But because the Tax Court misread Portland Golf Club as wholly dependent on demonstrating profitability, it had no occasion to evaluate whether evidence other than the club's chronic unprofitability might demonstrate an intent to profit. at 632. Losantiville is a preferred destination for charitable, civic & corporate organizations which enjoy the combination of great food, service, golf and value! For instance, if yourgroup had 80 players, the event would have $800 worth of credit to be used in the LCC Golf Shop to be divided at their discretion. Seacliff Country Club Cost. Contacting Justia or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship. The cost of the golf portion of your outing during April-October is$95 per player on Tuesday-Thursday and $125 per player on Friday-Monday, which includes cart fees, green fees, scoring, signage, set-up, and staffing. Company Type For Profit. Contact Paul Garrett to discuss membership details. Losantiville Country Club (Losantiville) is a private country club in Ohio operating as a Code Sec. And the Commissioner conceded during oral argument that because courts must consider more than just profitability when evaluating whether a club intended to profit, Section 183 factors could illuminate that intent. National membership allows those who have no residence within 45 miles of Maketewah Country Club. Industry: Country club, membership. 2017). He has several career achievements including the 2013 Southern Ohio PGA Assistant Golf Professional of the Year, Professional Advisory Staff member with Titleist and Foot-Joy, 2013 Member of the . See Portland Golf Club, 497 U.S. at 171 n.22, 110 S.Ct. Losantiville Country Club hosted unprofitable nonmember events for many years, consistently using those losses to avoid paying tax on its investment income. Hypothetically, let's say that I remain a member for 30 years. Losantiville Country Club. I.R.C. All Rights Reserved. We enjoy a long history of, and well-deserved reputation for, providing some of the Tri-state area's finest tennis courts. You already receive all suggested Justia Opinion Summary Newsletters. Tournaments at Losantiville CC. 1.6664-4(b)(1). Losantiville Country Club offers an exciting assortment of tennis options for all levels of players. Read 0 reviews of Losantiville Country Club. Golf Golf Members have unlimited access to all of Jefferson's amenities, including: the Clubhouse, Dining Room, Banquet Facility, Social Functions, Swimming Pool, Tennis & Pickleball Facility, Fitness Room and, most importantly, the Golf Course. Address: 3097 Losantiville Ave Cincinnati , Ohio, 45213-1398, United States . 1.183-1(d). 501 (c) (7) tax exempt organization. 1999) (horse breeders were unable to prove intent to profit when they lost ten times as much money as they made over twelve years, and the record reveals that the massive losses were not the result of startup expenses); Purdey v. Comm'r, 58 T.C.M. Updated on. Overview. We want to welcome you to the 2021tennis season at Losantiville Country Club. Although Losantiville booked losses for thirteen consecutive years on its nonmember events, it claims that a holistic review of its business practices reveals its intent to profit. Taxpayers cannot avoid section 183 and deduct large losses simply by conducting an unprofitable activity on a piece of land that is appreciating independently of or in spite of the activity. LaMusga v. Comm'r, 45 T.C.M. 497 U.S. at 171 n.22, 110 S.Ct. (CCH) 198. 3. 2018) Annotate this Case Justia Opinion Summary Losantiville Country Club hosted unprofitable nonmember events for many years, consistently using those losses to avoid paying tax on its investment income. In fact, the Tax Court noted that Losantiville stipulated that it and its accountants were aware of the Portland Golf Club[] precedent whose result, according to the Tax Court, clearly dictated that Losantiville was underpaying tax. 1990) (mounting losses over a twenty-year period and a lack of credible evidence that the taxpayer could ever realistically expect to recover losses demonstrated that petitioner did not intend to profit); W. Va. State Med. Plus, the IRS imposed accuracy-related penalties. 1.183-2(b).); Cannon v. Comm'r, 949 F.2d 345, 348 (10th Cir. The course features bentgrass greens, tees, and fairways. Part of the track's grandstand was converted into our original Clubhouse with showers and a locker room. Legal Name Losantiville Country Club. Reg. SOPGA Pro-1 Am (75% HDCP) at Losantiville C.C. Tollis v. Comm'r, 46 F.3d 1132 (6th Cir. Losantiville Country Club Careers and Employment About the company Industry Restaurants & Cafes Learn more Rating overview Rating is calculated based on 6 reviews and is evolving. Its not a country club, and its about a 30 min drive, but they do offer unlimited golf for 2k a year if youre just looking to play a lot of golf for cheap. Gross receipts from these events always exceeded direct expenses (the cost of the services provided). It brings about 410 members to the marriage, while Crest Hills,. A 501(c)(7) tax-exempt organization could not deduct losses from holding unprofitable nonmember events to avoid paying taxes on its investment income. Phone Number +1 513 631 4133. 3097 Losantiville Ave, Cincinnati, Ohio 45213, Hamilton County, A view from tee #1 at Losantiville Country Club, A view of hole #2 at Losantiville Country Club, A view of the 4th green at Losantiville Country Club, Add a GolfPass ratings badge to your website, Get a feed with the latest reviews for this course, From French Lick, Indiana, to Michigan's upper penninsula, the Midwest has plenty of places to golf and gamble. 91-552, at 71 (1969)). This project includes new forward tees on every hole, new back tees on a few holes, reshaping of some fairways, and renovation of every bunker on the golf course. Id. kenwood country club membership costwvu mechanical engineering research. In another, the Court noted that these factors do not apply to nonprofit social clubs. Instead, Losantiville asks this courtas it petitioned the Tax Courtto consider just two of the nine Section 183 factors: the businesslike way the club planned and conducted the nonmember events, and the appreciation of its land. Founded in 1902, our course was designed by the famous architect, Tom Bendelow - the "Johnny Appleseed of American Golf". The authority may be factual or legalor even ultimately prove meritlessas long as it is considerable and not overwhelmed by contrary legal authority. Estate of Kluener v. Comm'r, 154 F.3d 630, 639 (6th Cir. . Jefferson also offers a Junior Golf Membership for young professionals ages 39 and younger. Another option is Aston Oaks. Losantiville offers no persuasive argument for finding the Tax Court's conclusion clearly erroneous. You'll see the pristine beauty of our Championship Golf Course, grounds and majestic Clubhouse.You'll hear the laughter of friends and family truly enjoying themselves in our relaxed community atmosphere.You'll enjoy the aroma of freshly cut fairways as well as the savory culinary delights wafting from the kitchen. Whether you are a novice or a seasoned veteran, we will be able to help you find a game that fits your skill level. A club could offset these losses against investment income if it could demonstrate that it intended to earn gross income in excess of total costs. Id. In early 2016, LCC invested in new practice facilities. Employment at the course is verified by BlueGolf. The historic charm is now combined with a completely renovated clubhouse, making. Finding no reversible error in that decision, the Sixth Circuit affirmed. 3,287 were here. Lifestyle. Losantiville Country Club Cincinnati,OH is a private club featuring a clubhouse,18-hole golf course,. 501(b). In general, though, expect an average price between $700 and $25,000 for initial fees and then monthly rates on top of that, which will vary from around $70 all the way up to over $1,500 per month. tiny black tadpole looking bug in bathroom; ff14 plasmoid iron lake location; top 10 most dangerous areas in cape town; cockapoo rescue michigan; floris nicolas ali, baron van pallandt cause of death; We also acknowledged that several cases supported similar reshuffling of assets and differentiated any contradictory holdings. Although courts review holistically all relevant facts and circumstances when deciding whether an activity is a business or hobby, a long history of consistent and unexplained losses can overwhelm all other factors. Create Job Alert Glassdoor Glassdoor About / Press The cost of the golf portion of your outing during April-October is $95 per player on Tuesday-Thursday and $125 per player on Friday-Monday, which includes cart fees, green fees, scoring, signage, set-up, and staffing. The Section 183 Hobby Loss Factors May Establish Profit Motive. 17-2394 (6th Cir. On appeal, the Tax Court upheld this determination, reasoning that Losantiville did not intend to profit from its nonmember events. Losantiville derives income from several sources: membership dues and member-expenditures on food and drink, facility rentals to nonmembers, and interest and dividends on club investments. 2013). During the months of November-March the fee is $75 any day of the week. A caddie program with well trained young men and women, 8 Major Men's Club Tournaments, including an Invitational Member-Guest, A Ladies 18-Hole League with an annual Invitational Member-Guest, Reduced prices on all top of the line equipment in the GolfShop, Full service practice tee and greens, with sand bunkers, A short-game area that will have any imaginable shot available to practice. These 18 holes of golf were considered the gem of The Ridge Club and, next to the committed & passionate Membership, the new Club's most valuable asset. Keep scores and shots. Between 2010 and 2012, Losantiville offset its reported investment income with these losses under Section 162 and avoided paying any income tax. Losantiville CC, Cincinnati, OH | Private | Tom Bendelow | 6,493 yard | Avg Par 3: 189 When an organization is consistently unprofitable, even tougher. See Pullman-Standard v. Swint, 456 U.S. 273, 292, 102 S.Ct. The golf course has been continuously improved. Portland Golf Club, 497 U.S. at 16465, 110 S.Ct. We are committed toremoving obstacles and tearing down any barriers preventing you and your family from enjoying tennis at LCC. Serrano Country Club Cost. Headquarters Regions Great Lakes, Midwestern US. See, e.g., Atlanta Athletic Club v. Comm'r, 61 T.C.M. Contact Julia Whitney, Administrative Assistant, at julia@losantivillecc.com or by calling (513) 631-4133 for more information. The club was then reorganized as the Losantiville Country Club and incorporated on March 23, 1906, with the official dedication of the new Clubhouse taking place in May, 1907. 411, 430 (1979), aff'd, 647 F.2d 170 (9th Cir. The moment of clarity took place. Legal justification: Losantiville also contends that because it advocated for a novel application of existing law, its interpretation of Portland Golf Club provided reasonable cause for any underpayment. Learn more about FindLaws newsletters, including our terms of use and privacy policy. Guest Fees are $5 adult / $3 for children 10 and under. Food & beverage pricing is additional. $815 annually (includes $35 spring assessment) Use of swimming pool and tennis courts at no cost. We are committed toremoving obstacles and tearing down any barriers preventing you and your family from enjoying tennis at LCC. v. Comm'r, 299 F.3d 221, 234 (3d Cir. v. Comm'r, 115 T.C. Southern Ohio PGA. (CCH) 198 (2017). WHEELING | Enjoy 3 nights accommodations at Oglebay Resorts Wilson Lodge and 2 rounds of golf at Oglebay Resort Palmer & Jones Courses. 1.183-2. Section 501(c)(7) allows individuals to join together to provide recreational or social facilities or other benefits on a mutual basis, without tax consequences. Portland Golf Club v. Comm'r, 497 U.S. 154, 162, 110 S.Ct. The Tax Court's reading misses the Court's clarification: [a] taxpayer's intent to profit is not disproved simply because no profit is realized during a particular year. Id. Santa Ana Country Club Membership Cost. The leading golf architect of the time was Tom Bendelow, the Johnny Appleseed of American Golf. Such taxpayers generally must show that their intent to profit was thwarted somehow. 162, 212, the IRS uses the nine factors listed in Treasury Regulation 1.183-2(b) to distinguish between for-profit activities eligible for Section 162 or Section 212 deductions, and not-for-profit hobbies limited to deductions under Section 183. Sherwood Country Club Membership Cost. INWOOD, N.Y. - Peter Davidson, a member of Inwood Country Club since 1956, vividly remembers realizing just how unusual his Long Island club really was. LOSANTIVILLE COUNTRY CLUB v. COMMISSIONER OF INTERNAL REVENUE. Greater Cincinnati Team Challenge. GRAND RAPIDS/KALAMAZOO | Enjoy 3 nights accommodations at FireKeepers Casino Hotel and 3 rounds of golf at The Medalist Golf Club, Riverside Golf Club, and Binder Park Golf Course. Losantiville Country Club is a private Country Club founded in 1913 located in Cincinnati, Ohio, which operates golf, tennis and platform tennis, and swimming facilities, and provides food, beverages and services. If you represent an organization that is looking for a qualifed host for your outing, please contact either our General Manager, Jay Hingsbergen, orour Head Golf Professional, Chad Gilligan,for a price quote. 2023 Losantiville Country Club. kenwood country club initiation. Losantiville Country Club. ukraine russia border live camera /; June 24, 2022 An active member we got hold of told us that you can get access to a social membership for an initiation fee of $13,500, followed by $240 in dues, while the cost of a resident membership that would come with access to pool, dining, tennis, and golf, along with any other facilities offered by the club, will cost $80,000. ; see I.R.C. Turn LEFT on Woodford Rd and cross through Montgomery Road. In contrast, Losantiville marshalled virtually no evidence supporting its arguments for underpayment even under its argument for a novel application of Portland Golf Club. Below, please find related information to help you with your job search. Losantiville is a private country club in Ohio operating as a Section 501(c)(7) tax-exempt organization. Losantiville Country Club is the perfect and distinctive choice when you want to arrange that special occasion. About this app. Our golf course, founded in 1902, was designed by the famous architect, Tom Bendelow - revered as the "Johnny Appleseed of American Golf". Reg. When a lower court fails to apply the correct legal standard, the appropriate remedy is to remand the case to the trial court for reconsideration. Reg. Losantiville Country Club is a Please contact the clubhouse For membership rates & information Course Info Location and Contact 3097 Losantiville Avenue, Cincinnati, OH, 1398 losantivillecc.com update website (513) 631-4133 update phone No reviews at this time. Between 2002 and 2015, Losantiville hosted nonmember events to generate additional revenue and attract new members. For more information, or to check if your date is available, please contact either Chad Gilligan,Head Golf Professional, or Jay Hingsbergen, ClubhouseManager, to help you plan your event and assist you with choosing the perfect food and beverage options to compliment your day of golf. Mortensen v. Comm'r, 440 F.3d 375, 385 (6th Cir. All rights reserved. 162; see also Comm'r v. Groetzinger, 480 U.S. 23, 35, 107 S.Ct. "I find it rather difficult to make it clear to my children why we are not eligible, for from one point of view it isn't quite clear to me." (CCH) 684 (2006) (accounting for a taxpayer's land appreciation during a profit motive analysis because the property stood at the center of [her] horse[-breeding] activityshe housed, trained, bred, and fed her horses there). Treas. For example, [w]here land is purchased or held primarily with the intent to profit from increase in its value, and the taxpayer also engages in farming on such land, the farming and the holding of the land will ordinarily be considered a single activity only if the farming activity reduces the net cost of carrying the land for its appreciation in value. Id. 1998). The Code excuses this penalty if a taxpayer proves they have reasonable cause for the underpayment and acted in good faith. Id. Class "B" - A membership option that offers unrestricted use of the clubhouse, golf course, tennis courts, swimming pools, bowling and fitness center. Southern Ohio PGA. We're looking at a lifetime cost of $75,000 + 30 years of monthly fees, or $261,720, for a total of $336,720. Losantiville Country Club | Cincinnati OH 1985) (An unsuccessful farming operation cannot be carried on forever simply because the price of land in that general area is rising.). Aug 22, 2022. LCC offers a wide variety of dining experiences, casual to banquet. Maketewah Country Club 7 Country Clubs Bond Hill The club is the home course for the University of Cincinnati's Women's Golf Team. 1.00 2019 4.00 2020 Explore reviews by category 3.0 Work & Life Balance 2.4 Compensation & Benefits 2.4 Job Security & Advancement Management Culture 1994) (farm lost money for twenty out of twenty-one years and provided no evidence that these losses were attributable to unforeseen or fortuitous circumstances), with Faulconer v. Comm'r, 748 F.2d 890, 90001 (4th Cir. Losantiville Country Club v. Comm'r of Internal Revenue, No. There is no evidence, however, that the preparers had sufficient expertise to justify reliance, that petitioner provided them with necessary and accurate information, or that petitioner relied in good faith on the preparers' judgment. Losantiville Country Club, 114 T.C.M. Like other social clubs, Losantiville derives income from several sources: membership dues and member-expenditures on food and drink, facility rentals to nonmembers, and interest and dividends on club investments. In the spring of 2002, Losantiville CC and Crest Hills Country Club, established in 1939 and located near LCC in Amberly Village, voted to merge and become one. Losantiville Country Club hosted unprofitable nonmember events for many years, consistently using those losses to avoid paying tax on its investment income. Created and managed operations and member programming of Hillcrest Country Club consistent with the direction and policies established by the . At FindLaw.com, we pride ourselves on being the number one source of free legal information and resources on the web. The taxpayer bears this burden. Where You Belong! Id. Menu. Founded as a Jewish country club, in response to the unavailability of membership for Jews at established clubs of the time, LCC has not limited its memberships to Jews for decades; today's membership, although still reflecting the club's tradition and history, is a cross-section of Cincinnati demographics and is skewing younger on almost a weekly basis, especially as some of the neighboring communities like Pleasant Ridge continue to gentrify. You're all set! Take Galbraith Rd, stay in right hand lane, and turn RIGHT on Ridge Rd. Compare Hendricks v. Comm'r, 32 F.3d 94, 99 (4th Cir. As an example, even if you do not own your own tennis racquet, we have a selection of racquets you can use while you give us a try! Losantiville Country Club was founded in 1902 as is a Tom Bendelow designed golf course. Reg. Ass'n v. Comm'r, 882 F.2d 123, 125 (4th Cir. 91-552, at 71 (1969)). We now address the factual issue of whether Losantiville demonstrated a profit motive. Once again we want to welcome all members, and your guests, to what should be an exciting year of tennis at Losantiville Country Club. Losantiville's appeal raises two issues. See id. With green speeds an average of 10-11 on the Stimpmeter, putting becomes an artform. Losantiville Country Club's headquarters are located at 3097 Losantiville Ave, Cincinnati, Ohio, 45213, United States How do I contact Losantiville Country Club? the net cost of . 2780. That's a lot of money. 2002). Notable past members include William Taft, Woodrow Wilson as well as countless politicians and lobbyists.. Among other things, these factors ask whether the taxpayer has another major source of income, keeps complete books and records, seeks advice from an expert, and previously succeeded in similar ventures. Take I-71 northbound to the Ridge Road Exit. ), Take I-75 southbound to Galbraith Rd Exit LEFT exit. Don't worry, we can still help! Take I-71 southbound to Ridge Rd/Kennedy Ave Exit. LOSANTIVILLE COUNTRY CLUB, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Post author: Post published: February 17, 2023 Post category: recent car accidents in new mexico 2022 recent car accidents in new mexico 2022 All Rights Reserved. $65.00 monthly fee plus one time spring assessment of $35. Get a D&B Hoovers Free Trial. The original lease for the Losantiville Club, named after the original name of Cincinnati, was signed in February, 1902 upon the site of the old Oakley race track. Sharon Heights Golf & Country Club Cost. 2780. The Tax Court upheld these penalties and rejected Losantiville's assertions that it had reasonable cause: Petitioner's 2010, 2011, and 2012 returns were prepared by professionals. The Tax Court rejected this, assessing the Section 183 factors as inapplicable to 501(c)(7) organizations, and opining that Losantiville must actually profit to prove that it intended to profit. Disclaimer: Justia Annotations is a forum for attorneys to summarize, comment on, and analyze case law published on our site. Whether you'rea complete novice, an occasional player, a lapsed player, or a tournament player they want to help you to get on the courts this summer! Reg. Portland Golf Club v. Comm'r, 497 U.S. 154, 162, 110 S.Ct. The primary member is also able to add their spouse and all children under 21 years old, all of which are offered the same inclusions. Turn LEFT at the light off exit and get into the Right Hand Lane. The green complexes are very small and are a challenge to hit. 1993). Please try again. Because Losantiville's authority fails both on the merits and as a defense of reasonable cause and good faith, the Tax Court did not clearly err when it rejected Losantiville's reasonable cause defense and sustained the accuracy-related penalties. Losantiville Country Club (LCC) is a private Country Club founded in 1913 located in Cincinnati, Ohio, which operates golf, tennis and platform tennis, and swimming facilities, and provides food, beverages and services. Treas. But every year, the club reported a net loss after deducting the indirect expenses (general operating costs) attributable to the nonmember sales. But the reliance itself must be objectively reasonable: the taxpayer must have supplied the professional with all the necessary information to assess the tax matter and the accountant cannot suffer from a lack of expertise that the taxpayer knew of or should have known about. Neonatology Assocs., P.A. 2780; I.R.C. Feel free to contact us for more information about any golf home in Scottsdale at (602) 791-0536 or Carmen@TopScottsdaleHomes.com. Losantiville insisted that the intent to profit inquiry involves more than just mechanically computing whether the club made money on its nonmember events. GOLF - Losantiville Country Club - Cincinnati, OH GOLF Our golf course, founded in 1902, was designed by the famous architect, Tom Bendelow - revered as the "Johnny Appleseed of American Golf". FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Dining. Had the Tax Court considered the nine factors listed in the Treasury Regulations under Section 1.183-2, the club argues, it would have decided that the club operated with a valid profit motive. But in the small subset of cases where the record permits only one resolution of the factual issue, id., such a remand would be a waste of judicial resources, Estate of Hill v. Miracle, 853 F.3d 306, 317 (6th Cir. I l. enjoyed working at the country club, it was fun i met new people and one of my old teachers was a member at that club! See, e.g., Dodge v. Comm'r, 75 T.C.M.