- 8 - 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 typePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011