-5-
the cattle on the property, protect against the theft of cattle
and timber, and cut timber and haul it to the mill.
Around 1963, decedent and petitioner began an arrangement
under which petitioner furnished the labor to produce turpentine
from the timber on decedent's property. Petitioner and the
workers he hired tapped the pine trees on decedent's property to
produce sap. They took the sap to processing plants where it was
made into turpentine. Decedent received 25 percent of the
turpentine receipts, and petitioner received 75 percent.
Petitioner paid all of the expenses from his share. Petitioner
and decedent had a profit-sharing arrangement from the early or
mid-1960's until decedent died in 1992. Petitioner and decedent
agreed that petitioner would provide the know-how and labor to
manage and exploit decedent's timberland, and they would split
the profits.
Petitioner had authority to handle a substantial part of
decedent's business affairs. Decedent and petitioner jointly
owned some certificates of deposit and a safe deposit box. They
had signature authority on each other's accounts in which they
deposited money from their business. They each reported their
share of profits on their individual Federal income tax returns.
Petitioner managed most of decedent's assets. However, in
1988, decedent had 15 certificates of deposit, 1 checking
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011