Stanley M. Kurzet and Anne L. Kurzet - Page 45

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            Tahiti Property                                                                           
                  With regard to petitioners' Tahiti Property, our                                    
            conclusions are just the opposite.  Petitioners' Tahiti Property                          
            has inherently associated with it extensive recreational and                              
            personal aspects.  Petitioners have not satisfied their burden                            
            of proof that the Tahiti Property was held and managed by them                            
            for anything other than personal reasons.  Rule 142(a).                                   
                  Petitioners did not maintain complete and adequate records                          
            with regard to expenditures made on the Tahiti Property.                                  
            Petitioners’ assertion as to significant appreciation in the                              
            value of the Tahiti Property is neither credible nor persuasive.                          
            Petitioners claim that, as a result of their efforts and                                  
            improvements, by 1994, the fair market value of the Tahiti                                
            Property increased to $3.7 million and that, after their                                  
            purchase costs of $989,000 and additional costs of $597,000, for                          
            total alleged cash expenditures of $1,760,000, petitioners have                           
            realized on paper an economic gain of $1,940,000 in connection                            
            with the Tahiti Property.                                                                 
                  No credible evidence supports either the amount or nature                           
            of the claimed total expenses petitioners incurred on the Tahiti                          
            Property, nor the fair market value of the Tahiti Property.                               
                  We conclude that, during the years in issue, petitioners'                           
            ownership and management of the Tahiti Property constituted a                             
            personal activity with respect to which petitioners' expenses                             






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