Stanley M. Kurzet and Anne L. Kurzet - Page 18

                                               - 18 -                                                 
                  As explained by one of the timber experts with whom                                 
            petitioner frequently consulted and with which explanation we                             
            agree --                                                                                  

                  the age class of the timber when * * * [petitioners]                                
                  bought the property was roughly 30 to 40 years old.  It                             
                  was just reaching its peak in growth rate.  Quality was                             
                  becoming better by natural pruning of the limbs, log                                
                  diameters were increasing.  It was probably growing at                              
                  10 percent a year, so it had been -- the worst thing                                
                  * * * [petitioners] could have done would have been cut                             
                  the timber shortly after they bought the property,                                  
                  which the recruise shows now that that was the smart                                
                  thing to do.  The volume’s -- over doubled.                                         

                  After 1989, even though prices for cut timber increased,                            
            petitioner has continued to postpone the cutting and sale of                              
            timber on the timber farm in part because the trees on the timber                         
            farm were approaching 60 years of age -- at which point in time                           
            trees move into a separate commercial class for trees over 60                             
            years of age and increase in value by approximately 30 percent.                           
                  From the time of purchase in 1985, until the time of trial                          
            in 1995, the volume of timber in the trees on petitioners’ timber                         
            farm has approximately doubled.                                                           
                  As of May of 1995, the assets on petitioners’ timber farm                           
            have a fair market value of approximately $3,524,000, as set                              
            forth below:                                                                              
                                                          May 1995                                    
                  Timber Farm Assets                      Fair Market Value                           
                  Timber                                       $2,100,000                             
                  Buildings and improvements                   908,000                                
                  Equipment and machinery                      516,000                                
                                          Total                $3,524,000                             



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