Stanley M. Kurzet and Anne L. Kurzet - Page 24

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            the trip as having a dual purpose (namely, to ski and to meet                             
            with a contractor doing work on one of petitioners'                                       
            condominiums).                                                                            

            Personal Residence                                                                        
                  As indicated, during 1987, 1988, and until September 8,                             
            1989, petitioners’ principal residence was located at 394 South                           
            Esplanade, Orange, California.  This residence was an elegant 24-                         
            room home on 3.5 lushly landscaped acres.  It had a swimming                              
            pool, garden patio, servants' quarters, a garage workshop, garden                         
            equipment buildings, and parking for up to approximately 40 cars.                         
                  Petitioner had rooms in this residence in which petitioner                          
            performed paperwork and computer tasks associated with his                                
            various activities.  In their residence in Orange, California,                            
            petitioners also performed bookkeeping, maintained reference                              
            manuals and industry publications, and paid numerous bills                                
            relating to their many activities.                                                        
                  Petitioners' residence consisted of three levels.  In the                           
            partial, walkout basement were located two rooms in one of which                          
            computers and a copy machine were placed, a bathroom, a furnace                           
            room, a small wine room, and a family room.                                               
                  On the main level were located a study or library in which                          
            petitioner occasionally met with others on business matters, the                          
            main living room, a large entry, a dining room, three bedrooms,                           
            three full baths, and one-half bath.                                                      





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