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Petitioners allege that from 1984 through 1994 their
cumulative cash expenditures relating to purchase and
improvements undertaken on the Tahiti Property totaled
$1,760,000.
Lear Jet
In 1984, because of anticipated frequent travel, petitioner
purchased a Lear jet airplane for $2 million. The Lear jet was
used by petitioners for personal travel and to travel to
petitioners' timber farm in Oregon, to petitioners' Tahiti
Property, to computer symposiums, to machinery auctions, to pick
up equipment and parts needed in petitioners' various activities,
and to Park City, Utah, where petitioners skied and eventually
bought two condominiums and two vacant lots, on one of which
petitioners built a large personal residence.
When traveling to the timber farm and to the Tahiti
Property, petitioner often would transport in the Lear jet
equipment and supplies that would be used at the timber farm and
on the Tahiti Property. Occasionally, other family members would
travel with petitioners in the Lear jet.
During 1987 through 1989, the first-class air fare between
Orange, California, where petitioners’ primary residence was
located, and North Bend, Oregon, the airport closest to
petitioners' timber farm, was approximately $1,600 per person. A
commercial airplane trip between these two cities would take
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