Stanley M. Kurzet and Anne L. Kurzet - Page 15

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            and other equipment without hiring expensive machinists and                               
            equipment repairmen.                                                                      
                  Again, we note that petitioner purchased for the timber                             
            farm old and used farm and machine shop equipment because it was                          
            much cheaper than purchasing new equipment, because much of the                           
            equipment would not be used frequently on the property, and                               
            petitioner therefore had no need for new equipment, and because                           
            of petitioner's talent and competence in restoring and                                    
            maintaining mechanical equipment.                                                         
                  Petitioner was able to acquire from auctions a large                                
            variety of used farm equipment, to restore the equipment, and, as                         
            of the time of trial, in the barns located on the timber farm,                            
            petitioner maintained in excellent condition and stored for use                           
            on the timber farm approximately 30 pieces of old but operational                         
            farm equipment.  The parties and their experts are in agreement                           
            as to the excellent restoration and high quality maintenance of                           
            the equipment located on the timber farm.                                                 
                  From the time petitioners purchased the timber farm in June                         
            of 1985, until September 8, 1989, petitioners’ primary residence                          
            was in Orange, California.  From September 8, 1989, through the                           
            time of trial, petitioners' primary residence was in Park City,                           
            Utah.                                                                                     
                  Petitioners traveled to their Oregon timber farm                                    
            approximately 4 or 5 times a year, and on each trip petitioners                           
            typically would spend a number of weeks on the timber farm.  In                           




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