Stanley M. Kurzet and Anne L. Kurzet - Page 2

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                                                                                    Accuracy-         
                                                                                    Related           
                              Additions to Tax                    Penalty                             
                                             Sec.                                                     
                                 Sec.      6653(a)(1)/        Sec.        Sec.      Sec.              
         Year    Deficiency   6651(a)(1) 6653(a)(1)(A)    6653(a)(1)(B)   6661      6662(a)           
         1987    $440,539     ---         $22,027                *        $110,135     ---            
         1988    202,360      ---         10,118               ---        50,590       ---            
         1989  215,930   $7,845      --- ---    ---  $43,186                                          
                 *  50 percent of interest due on portion of underpayment                             
                 attributable to negligence.                                                          

                  In an Amendment to Answer, respondent increased the                                 
            deficiency, addition to tax, and accuracy-related penalty for                             
            1989 to $404,418, $17,269, and $80,883, respectively.                                     
                  The primary issues for decision are:  (1) Whether, during                           
            the years in issue, petitioners' ownership and management of a                            
            timber farm property near Coos Bay, Oregon, constituted a trade                           
            or business activity entered into for profit, as petitioners                              
            contend, or a personal, nonbusiness, not-for-profit activity, as                          
            respondent contends; (2) whether petitioners' investment in                               
            property in Tahiti constituted a for-profit investment under                              
            section 212; (3) the deductibility under section 162 or section                           
            212 of expenses relating to petitioners' use of a Lear jet to                             
            travel, among other places, to their Oregon timber farm property                          
            and to their property in Tahiti; and (4) to what extent expenses                          
            of petitioners' residence in Orange, California, qualify as home                          
            office expenses under section 280A.  Various additional and                               
            alternative issues are also for decision (e.g., if petitioners'                           
            timber farm constitutes a for-profit trade or business activity,                          





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