Stanley M. Kurzet and Anne L. Kurzet - Page 33

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            petitioner's labor was contributed, and no wage or fee was paid                           
            to petitioner for his labor on the timber farm).                                          
                  Petitioners' total $147,643 cost for purchase and                                   
            improvement of the mobile unit was capitalized, and depreciation                          
            thereon was claimed by petitioners as an expense of the timber                            
            farm.                                                                                     
                  The primary difference between petitioners’ original Federal                        
            income tax returns and petitioners’ proposed revised Federal                              
            income tax returns, all of which were prepared by accountants and                         
            experienced tax return preparers, relates to the Lear jet.  On                            
            petitioners’ original Federal income tax returns, the Lear jet                            
            was treated as a separate trade or business activity, and all                             
            noncapital costs thereof were treated as current business                                 
            expenses, including depreciation.  On the proposed revised                                
            returns, the Lear jet is not treated as a separate business                               
            activity.  Rather, based on the Lear jet’s flight logs, the                               
            noncapital costs of the Lear jet (including depreciation) are                             
            allocated to the various separate other activities of petitioners                         
            and treated as deductible section 162 business expenses,                                  
            deductible section 212 expenses, or as nondeductible personal                             
            expenses depending on the business, investment, or personal                               
            nature of the underlying activity to which the expenses are                               
            allocated.                                                                                
                  On petitioners’ proposed revised Federal income tax returns,                        
            petitioners treat their Tahiti Property as a for-profit                                   




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