Option 3 · Full Build Approved 2026-07-04 RV resort + entertainment Confidential

Riddler's Run
+ White Rabbit Entertainment

An owner-built RV resort and entertainment venue, underwritten as one reconciled model. The thesis is a 100% first-year bonus-depreciation shield under OBBBA §168(k) paired with real-estate-professional (REPS) treatment, carrying levered returns that stay intact after the exit-disposition tax is modeled honestly.

560 Town Center Dr, Jarrell TX 78644  ·  13|7 Frameworks LLC  ·  Analysis 2026-07-05

Grand total cost
$14,669,141
Reconciled baseline + golf + parking + contingency
Year-1 tax shield
$3,527,928
Bonus-eligible basis × 37% REPS rate
Post-tax IRR
28.9%
Levered, net of exit-disposition tax (modeled)
Equity required
$4,400,742
30% of cost · 70% LTV senior debt
01

Overview

Riddler's Run pairs an RV resort with an entertainment venue (White Rabbit) on a single Jarrell, TX site off the I-35 Exit 275 frontage. The build was approved on 2026-07-04 as Option 3 — the full build — and modeled at a grand total project cost of $14,669,141.

The financial case rests on two levers. First, the resort is land-improvement-heavy — lagoon, RV pads, turf, courts, and parking — which pushes a large share of basis into 5- and 15-year cost-segregation buckets that qualify for 100% first-year bonus depreciation under OBBBA §168(k) (IRS Notice 2026-11). Second, real-estate-professional (REPS) treatment at a 37% rate lets that depreciation shelter non-passive income, producing an estimated $3,527,928 Year-1 tax shield.

This model reconciles five advisory disciplines — Finance, CPA, CFA, Insurance, and Legal — into one artifact. It also carries the unflattering findings openly: a Year-1 debt-service shortfall during lease-up, 1099 crew classification exposure, and several assumptions that a property-level trailing-twelve would firm up.

Deal snapshot

  • Asset: RV resort + White Rabbit entertainment venue
  • Entity: 13|7 Frameworks LLC
  • Site: 560 Town Center Dr, Jarrell TX 78644
  • Scope: Option 3 Full Build, approved 2026-07-04
  • Tax method: OBBBA §168(k) 100% bonus · REPS 37%
  • Hold: 10-year, modeled with an exit sale in Year 10
  • Stabilized revenue (P50): $4,954,996
  • Stabilized NOI (Yr 3): $1,684,699
02

Cost basis, sources & uses

Cost basis

Revised baseline$13,758,341
Golf zone (newly priced)$688,500
Added parking · 150 spaces$139,500
Soft costs / contingency (10% on new adds)$82,800
Grand total project cost$14,669,141

Original total $14,620,041 less $861,700 of confirmed cuts gives the revised baseline. CPA depreciable basis ties exactly to this grand total under the 100%-improvements assumption. Note: ~$5.25M of the baseline scope (lagoon, White Rabbit structure, site work, amenity station, micro-cabins) is not itemized in the source model — a labeled data gap.

Uses — equity & debt

Equity required (30%)
First-in during construction draw
$4,400,742
Senior debt (70% LTV)
25-yr amort · 7.5% rate
$10,268,399
Annual debt service
Principal + interest, level
$910,591
Construction interest carry
18-mo S-curve, capitalized
$540,165

Draw is equity-first for the first six months, then loan-funded, on a standard 18-month S-curve (an assumption on curve shape). The capitalized interest carry confirms the lender's interest-reserve requirement at closing.

03

Returns — four lenses

The deal is shown four ways so the tax mechanics are legible. The headline figure is the last row: levered, post-tax, and net of the modeled Year-10 exit-disposition tax — the honest number.

Return matrix

BasisNPV @ 12%IRR
Unlevered, pre-tax$1,560,71013.5%
Levered, pre-tax$4,048,48721.0%
Post-tax, excl. exit tax31.8%
Post-tax, incl. exit tax$4,162,28028.9%

All figures are modeled estimates, not guaranteed returns. NPV discounted at 12%. The 31.8% (excl. exit tax) row ties to the prior v2 basis; the 28.9% row nets out the Year-10 disposition tax this version adds.

Exit-disposition tax (Year 10)

Net sale price (after selling cost)$24,180,189
Adjusted basis at sale$3,817,740
Total gain$20,362,449
§1245 ordinary recapture @ 37%$1,899,654
Unrecaptured §1250 @ 25%$1,429,300
LTCG on appreciation @ 20%$1,902,210
Estimated total exit tax$5,231,164

Estimate. §1245 personal property and §1250 additional depreciation taxed as ordinary at the 37% REPS rate; unrecaptured §1250 at 25%; residual appreciation at 20% LTCG. NIIT and state tax not modeled. Formal cost-segregation study and tax-advisor review required.

04

Financing & coverage

Debt-service coverage ratio (DSCR) by year on the P50 revenue build. Year 1 does not cover debt service during lease-up; coverage crosses 1.0× in Year 2 and stabilizes near 1.85× from Year 3.

DSCR by year — P50 revenue build

Below 1.0× — does not cover debt service 1.0× and above — covers debt service

Year-1 NOI $544,158 falls short of the $910,591 annual debt service, giving a 0.60× coverage ratio. A debt-service reserve of roughly $366,433 covers the Year-1 shortfall; the ~$540,165 construction interest carry sits alongside it as a lender interest reserve at closing.

05

Sensitivity

Post-tax IRR across the two assumptions that move the model most: the exit cap rate and the stabilized NOI margin. The base case (8.0% cap, 34% margin, 28.9% IRR) is outlined.

Exit cap ↓ / NOI margin →30%34%38%
Cell = levered post-tax IRR, net of exit-disposition tax. NOI margin and exit cap are assumptions — no published RV-resort series exists — and are stress-tested here. A property-level trailing-twelve or broker opinion of value would firm them.
06

Risks & findings

Surfaced, not buried. The two high-severity items are structural to the deal and require a decision or a reserve; the rest are assumptions to confirm.

High

Year-1 DSCR 0.60× during lease-up

Year-1 NOI $544,158 is below the $910,591 annual debt service. A debt-service reserve of ~$366,433 is required for Year 1 (Year 2 recovers to 1.22×). The construction schedule confirms a lender interest reserve (~$540,165 carry) at closing. Stabilized coverage is healthy at 1.85×.

High

1099 traveling crew — classification & Workers' Comp exposure

13|7's traveling crew is 1099. Texas Workers' Comp is non-subscriber-optional, and a standard WC policy does not cover 1099 workers — they need Occupational Accident plus contingent liability, or must be run W-2 on a WC policy. A 1099 crew directed like employees creates IRS/TWC misclassification exposure (back taxes, penalties, uninsured-injury liability). Decision required. Separately, any subcontractor without valid WC has its payroll charged back to 13|7's WC at audit — enforce COIs and additional-insured status before mobilize.

Med

NOI margin (34%) & exit cap (8.0%) are assumptions

No published RV-resort NOI-margin or cap-rate series exists. Stress-tested across the sensitivity grid; a property-level trailing-twelve or broker opinion of value would firm them.

Med

$5.25M of baseline scope is unitemized

Named P1 ($3,836,868) + P2 ($4,668,016) = $8,504,884, which is $5.25M short of the $13,758,341 baseline. The source model does not itemize the lagoon, White Rabbit structure, site work, amenity station, or micro-cabins.

Med

Exit-disposition tax materially lowers post-tax IRR

The prior version omitted all exit tax. This version estimates $5,231,164 of §1245/1250 recapture plus LTCG on the ~$20.4M gain, cutting post-tax IRR from 31.8% to 28.9%. Estimate — formal cost-seg and tax-advisor review required; NIIT/state not modeled.

Low

RV pad count back-solved (~67)

The revenue build implies roughly 67 RV pads at a sourced ADR of $120, 76% occupancy, and a 45% RV revenue share (an assumption). Confirm pad count and stream mix against the site plan.

Low

Land basis assumed $0 (100% improvements)

If raw land cost is embedded in the $14.67M, non-depreciable land must be carved out and the Year-1 shield plus recapture re-cut. This is the one open reconciliation item.

07

Insurance & legal

Insurance program

  • Operating (finished resort): $10,500/yr est. — GL $5,000 + liquor $3,000 + event $2,500. Commercial property + business interruption to be quoted at stabilization.
  • GC / construction-period: builder's risk $220,037 (1.5% of construction) + payment/performance bonds $146,691 — both one-time.
  • Payroll-driven (broker quote): contractors CGL, $5M+ excess/umbrella, commercial auto for the traveling crew, design-build E&O, and pollution liability.
  • Subcontractors: each must carry CGL + WC + Auto, name 13|7 as Additional Insured with Waiver of Subrogation and Primary/Non-Contributory. Collect COIs before mobilize.

Legal & permits

  • TABC: BG — Wine & Malt Beverage (beer & wine only), $1,900/2yr. Not the over-scoped Mixed Beverage full-liquor permit.
  • Permits: Williamson County site plan, per-phase building permits, OSSF/TCEQ (RV sewage may need an aerobic WWTP), TxDOT access at I-35 Exit 275, stormwater/detention.
  • Fire rule enforced: no fire features anywhere — all replaced with LED-wrapped palm trees, so NFPA 58 is not triggered.
  • Entity/REPS: confirm single- vs multi-member LLC; document >750-hr material participation to sustain the non-passive treatment behind the Year-1 shield; confirm land title for the basis carve-out.
08

Terms, assumptions & methodology

Traceability. The advisory stack — Finance → CPA → CFA → Insurance → Legal — was run as one reconciled model. Shared figures (cost basis, revenue P50, depreciable basis, builder's-risk base) tie out across all five disciplines. Every figure on this site traces to a source, a driver, or a labeled assumption; none are fabricated.

Tie-outs. CPA depreciable basis ($14,669,141) equals the Finance grand total. CFA revenue build P50 ($4,954,996) reconciles to the Finance baseline ($4,954,000). Tax method is OBBBA §168(k) 100% bonus (IRS Notice 2026-11) with REPS at 37%.

Open items & assumptions

  • Land basis assumed $0 (100% improvements) — the one open reconciliation item.
  • RV pad count back-solved to ~67; confirm against the site plan.
  • NOI margin (34%) and exit cap (8.0%) are assumptions; no published RV-resort series exists.
  • $5.25M of baseline scope is unitemized in the source model.
  • Micro-cabin cost pending owner input.
  • Cost-segregation split (20% / 45% / 35% across 5/15/39-yr) is an analyst assumption pending an engineering-based study.
  • Post-construction property + BI insurance to be quoted at stabilization.