- 42 - eventually to realize substantial overall net profits therefrom at the time the trees are cut and sold. Petitioners' bookkeeping was amateurish but extensive. (2) Expertise: Petitioners were innovative, attentive, informed, hardworking, capable, and no-nonsense owners and managers of the timber farm. They hired experienced employees, and, where necessary, they hired experts to advise them on aspects of the timber farm. (3) Time and effort: Petitioner worked extremely long hours and put a great deal of effort in maintaining and improving the timber farm, and he expected the same of his employees. (4) Appreciation in value of assets: Petitioners' good- faith intent and expectation that the timber on the timber farm would appreciate in value are clear and have been proven accurate. (5) Success in other activities: Petitioner's success as a businessman in a number of activities is unquestioned. (6) and (7) Income or losses realized: Profits and appreciation that appear to be available from petitioners' timber farm have not yet been realized or cashed in. But they are there, ready to "harvest", in amounts significantly in excess of petitioners' costs. Respondent argues that under a proper calculation of the costs that petitioners incurred on their timber farm,Page: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
Last modified: May 25, 2011