Julian P. Kornfeld - Page 2

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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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