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the Super Trust in fiscal year 1989. Petitioner concedes that it
should have reported this income for 1989. Petitioner's failure
to report the income did not result in an income tax deficiency
because petitioner's income was more than offset by fuel excise
tax credits in 1989.
3. Petitioner's Expansion Plans
In 1988, petitioner decided to develop a comprehensive land
use plan for the 8,000 acres adjoining its dairy. Petitioner
believed that the area around the dairy would be developed and
that petitioner would move.
Petitioner projected in category two of its CEP for fiscal
year 1988 and in category one of its CEP for fiscal year 1989
that it needed to spend $1,500,000 on land. Petitioner
negotiated to buy property from the Roberts family (the Roberts
property) in 1989. However, petitioner did not buy the Roberts
property.
During the years in issue, petitioner's board learned that
Union Camp Corp. planned to develop 56,000 acres of land that it
owned adjacent to and south of petitioner's property. The Union
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