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in issue, petitioners filed Forms 1040, U.S. Individual Income
Tax Return, using the filing status of "Married filing joint
return".
In 1980, petitioners acquired title to approximately 140
acres of real property (the Ashland property). The property is
located in Ashland, New York, in the Catskill Mountains and
within 15 minutes of a ski area called Ski Windham. At the time
of purchase, a small farmhouse and garage were located on the
property. Petitioners have since used the house as a vacation
home.
Mr. Spera, a metallurgical chemist by trade, was the sole
shareholder of GRC. During the years in issue, GRC's operations
were located in a building in Hempstead, New York (the Hempstead
Building). GRC, incorporated on August 2, 1977, was in the
business of assaying and melting precious metals. GRC's assaying
business consists of ascertaining the weight and the purity of
gold and silver. The melting business consists of liquefying
metal. GRC also conducts a sweeps operation out of the Hempstead
Building. The sweeps operation services customers in the
manufacturing, jewelry, and electronics fields. These businesses
use precious metals and create a byproduct of waste materials.
GRC burns, crushes, sieves, assays, and sends these waste
materials to a smelter. GRC filed its 1987 through 1994 Forms
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