Taxes and Flying Clubs

I'm hoping folks on this newsgroup can give me some ideas to take back to my
flying club. We currently have 24 members and 3 aircraft. Through years of
less than stellar management the officers the club has found itself in the
position of facing some very expensive upgrades. As a result the membership
has commission a group to look at how the club funds itself. One of the
recommendations that the review group is going to put forth is that the
hourly rate charged members while flying include reserves for upgrades as
well as an amount to offset the costs of overhauls.

In the past these things have been done by borrowing money and then using
the monthly dues to make the payments in addition to insurance, hangar
etc...

The club's accountant has pointed out that changing how we are handling the
funds will make us subject to taxes on the money being set aside for
overhauls and upgrades. What have other folks/clubs done to get around
this?

If it helps our club has one share per member.

Thanks for any input.

Chris