Stanley M. Kurzet and Anne L. Kurzet - Page 8

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            expenses, as compared with petitioners' original Federal income                           
            tax returns as filed with respondent, petitioners' proposed                               
            revised returns, with regard to these new items and issues, are                           
            to be ignored except to the extent that petitioners have filed                            
            with the Court amendments to their pleadings to properly raise                            
            new issues with regard to such alleged reductions in income and                           
            alleged increases in expenses.  Rule 41.                                                  
                  We also note that as a result of information provided by                            
            petitioners to respondent during the course of the audit and                              
            litigation, including the proposed revised returns, respondent                            
            has significantly revised and lowered her original deficiency                             
            determinations against petitioners.                                                       

            Timber Farm                                                                               
                  Prior to 1984, petitioner had no experience in the timber                           
            industry, in farming, or in cattle raising.  Petitioner, however,                         
            in 1984 and 1985, after receiving approximately $20 million from                          
            his sale of ALS, investigated and consulted with a number of real                         
            estate and forestry experts about the timber industry and                                 
            forestry management.                                                                      
                  Specifically, with regard to 621 acres of timber property in                        
            Coos County, Oregon (timber farm), petitioner inspected the                               
            timber farm and the trees growing thereon with real estate agents                         
            and forestry experts.  Petitioner and the experts considered the                          
            type and quantity of trees growing on the timber farm, the type                           





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