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amortize the cost of acquiring a life interest in tax-exempt
bonds where others simultaneously acquired the remaining
interests.
The case was submitted fully stipulated under Rule 122.1
All of the stipulated facts, including those contained in the
attached exhibits, are found accordingly.
Petitioner resided in Oklahoma City, Oklahoma, at all
relevant times, including the time when he filed his petition
herein. He filed timely individual income tax returns for 1990
and 1991.
Petitioner is an experienced lawyer, particularly in the
fields of business and tax law.2 He has two daughters, Meredith
Kornfeld (Meredith) and Nancy Kornfeld (Nancy), both of whom were
adults and college graduates at all relevant times. At those
1 All statutory references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
2 The stipulation of facts contains a detailed description of
petitioner's experience and of his analysis of the pertinent
authorities prior to entering into the transactions involved
herein. Petitioner has emphasized the description and the
analysis presumably to persuade the Court that his "expertise"
should be a significant factor influencing us to arrive at a
conclusion favorable to him. Respondent has utilized the
description presumably to persuade us that petitioner's tax
motivation predominated and should persuade us to decide the
instant case in her favor. We consider petitioner's background
and analysis peripheral (as to respondent's use of it) and
irrelevant (as to petitioner's use of it) to the accomplishment
of the task before us, namely, independently to reach our own
conclusions based on the stipulated factual elements of the
transactions involved.
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