Stanley M. Kurzet and Anne L. Kurzet - Page 42

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            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,                                     




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