Stanley M. Kurzet and Anne L. Kurzet - Page 19

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                  Petitioners never raised any cattle or sheep on the timber                          
            farm, and, in approximately 1989, petitioners abandoned plans to                          
            raise cattle and sheep on the timber farm due to lack of adequate                         
            summer rainfall to sustain a second harvest of hay that the                               
            cattle and sheep would need.                                                              
                  There were no recreational amenities or activities of any                           
            kind on the timber farm -- no tennis court, no putting green, no                          
            swimming pool, no horses, no lake, no boating, no fishing, no                             
            recreational or resort facilities.  The evidence is clear that                            
            petitioners' timber farm was not owned, operated, or used by                              
            petitioners for recreation, leisure, or other personal purpose.                           
                  Petitioner personally set up and maintained computerized                            
            accounting records with respect to expenses relating to the                               
            timber farm.  As mentioned earlier, petitioners' records were not                         
            totally adequate, and expenses relating to the timber farm were                           
            often mislabeled or associated with the wrong activity.  The                              
            evidence establishes, however, and respondent does not dispute,                           
            that all of the expenses claimed on petitioners' original Federal                         
            income tax returns and all of the expenses claimed on                                     
            petitioners' proposed revised Federal income tax returns with                             
            respect to the timber farm were incurred and are fully                                    
            substantiated -- as to amount and payment -- by petitioners'                              
            books and records.                                                                        






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