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THE WITNESS: We have not allocated any to personal
here.
THE COURT: Why not?
THE WITNESS: Mr. -- that was based on conversations
with Mr. Kurzet that -- that his sole purpose for the
additional insurance -- this is liability over and above the
homeowners which we have taken personal portion, but for
this --
THE COURT: Well, they have three and a half acres of--
THE WITNESS: Right.
THE COURT: -- of country estate. They have a little
swimming pool in the back yard, and you don’t allocate
anything to personal?
THE WITNESS: We didn’t.
THE COURT: Why not? Did they use the swimming pool
for consulting?
THE WITNESS: No.
THE COURT: What do you think they used the swimming
pool for?
THE WITNESS: It’s personal.
THE COURT: Did you know there was a swimming pool
there?
THE WITNESS: Yes.
THE COURT: And you did not allocate any of the
umbrella liability policy to personal?
THE WITNESS: Not on this policy.
Petitioners' original Federal income tax returns for 1985
through 1989, reflect, among other income, the following annual
income, before expenses, from consulting, interest on bank and
security investments, and rent:
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