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incorporated herein by this reference. All section references
are to the Internal Revenue Code in effect for the years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure, unless otherwise indicated.
Petitioner resided in Osceola, Wisconsin, when he filed the
petition in this case. He was employed as a pilot for Northwest
Airlines, flying out of Minneapolis, Minnesota, during the years
in issue. Osceola, Wisconsin, is approximately 60 miles from
Minneapolis, Minnesota.
Petitioner conceived the idea of a wind-powered distillery
in 1977 to produce ethanol, an alcohol-based fuel. In 1980, he
began his efforts to construct such a distillery on a parcel of
land across the road from his residence. The only building
permit petitioner has secured for the property in question is one
which allows him to construct a single family residence.
Petitioner has not sought permits from the Bureau of Alcohol,
Tobacco and Firearms (ATF) to produce alcohol. ATF has informed
petitioner that he may not commence alcohol production without
ATF approval. Petitioner did not seek approval from the State of
Wisconsin to store ethanol fuel on his property despite being
informed by a State inspector that approval was required for
underground storage tanks such as the ones he was maintaining on
his property.
Petitioner has degrees in aeronautical engineering and law.
He attended, but did not earn a degree from, Massachusetts
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