Estate of Helen Bolton Jameson, Deceased, Northern Trust Bank of Texas N.A., Independent Executor - Page 6

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          Property was landlocked and dependent on private access rights;             
          the Timber Property had an internal road system and direct access           
          to public roads.                                                            
               B.   Holding Company Status                                            
               In its 1990 and 1991 Forms 1120, U.S. Corporation Income Tax           
          Return, Johnco was designated a personal holding company,                   
          consistent with the nature of Johnco's business.  Johnco had only           
          one employee, Andrew, who served as its president and chief                 
          operating officer.  Over 80 percent of Johnco's gross revenue was           
          derived from the sale of timber.  Johnco harvested timber from              
          the Timber Property very conservatively.  The amount of timber              
          harvested annually was limited to an amount approximately equal             
          to, or less than, the Timber Property's annual growth.4  Johnco             
          did not actually cut the timber that was harvested or employ                
          personnel or own any of the equipment necessary to harvest                  
          timber.  Potential buyers placed bids with Johnco to purchase               
          timber and were responsible for its cutting and transportation              
          off the Timber Property.  Although Andrew was the sole employee             
          of Johnco, management of the timber on the Timber Property was              
          generally handled by an outside consulting forester, who                    
          monitored the property and advised Johnco regarding the specifics           
          of harvesting timber, for a commission based on timber sales.               
          Until late 1990, Johnco's outside consulting forester had been              

               4 Limiting the annual harvest to annual growth is referred             
          to as "sustainable yield"; this method maintains an approximately           
          constant volume of timber in place.  Harvesting less than annual            
          growth results in an increase in timber volume on a given tract.            

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