Stanley M. Kurzet and Anne L. Kurzet - Page 16

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            1987, 1988, and 1989, petitioners spent 127, 139, and 80 days,                            
            respectively, on the timber farm.                                                         
                  On the days on which petitioners were at the timber farm,                           
            petitioner worked constantly on the timber farm -- designing and                          
            planning repairs and improvements, personally operating heavy                             
            equipment such as graders, and working to improve and maintain                            
            roads and buildings, to clear brush, to build new roads for fire                          
            protection and for use in eventual harvesting of the timber.                              
                  When at the timber farm, Mrs. Kurzet worked on the records                          
            and other chores relating to maintenance of the timber farm, and                          
            petitioners generally worked from sunrise until sunset on various                         
            projects relating to the timber farm.                                                     
                  When petitioner was not working on the timber farm,                                 
            petitioner would leave detailed written instructions for the                              
            employees to follow in his absence, listing priority projects on                          
            the timber farm on which the employees should work.                                       
                  In 1985, petitioners purchased a modest mobile unit and                             
            placed it on the timber farm for use as an office and on-site                             
            sleeping accommodation for the days they were at the timber farm.                         
            Two of the rooms in the mobile unit were used as a computer room                          
            and work room in connection with the timber farm.  One room was                           
            used as a bedroom for petitioners.  The kitchenette and dining                            
            area were used frequently for paperwork, recordkeeping, meetings,                         
            and an office for the timber farm.                                                        






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