Frederick G. Harrison, Sr. and Estate of Catherine Harrison, Deceased - Page 4

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               Petitioners owned a home and a farm in Marlton, New Jersey,            
          which were situated on 44 acres.  Petitioners lived at the farm.            
          Petitioners also owned a second home in Tucson, Arizona, which              
          they purchased in 1985.  Petitioners owned the New Jersey farm              
          and residence and the Arizona residence with no outstanding                 
          mortgages on either property.  Petitioners purchased another                
          residential property in Atco, New Jersey, which they bought in              
          1989 to use as a rental property.  They purchased the Atco                  
          property for $80,000 and had a $60,000 mortgage on the property.            
               Petitioners reported adjusted gross income on their tax                
          returns for 1987, 1988, and 1989 in the respective amounts of               
          $56,692, $247,041, and $133,235.  Petitioners' adjusted gross               
          income for 1989, without regard to losses claimed for treasure              
          hunting and gold mining, would have been $334,764.                          
               Mr. Harrison first developed an interest in gold mining                
          through a company called Christine Enterprises in 1985.                     
          Christine Enterprises conducted its mining operation in the                 
          Sonora section of Mexico.  Christine Enterprises conducted this             
          gold mining activity with an individual named Thomas Daley.  Mr.            
          Daley was an engineer who had studied mining and geology at                 
          Tucson University.  Mr. Harrison sought Mr. Daley's assistance in           
          an attempt to find gold nuggets by placed mining.4  Mr. Harrison            
          did not find any gold with Christine Enterprises.  In addition to           

               4  Placed mining is a form of panning for gold flakes and              
          nuggets in streams and rivers after the winter thaw.                        




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