Robert and Karen O'Connor - Page 6




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                           Pasture      Almond         Livestock                      
               Year        Rent         Sales          Sales                          
                                                                                     
               1990           -0-       -0-            -0-                            
               1991        $2,692       -0-            -0-                            
               1992        5,620        -0-            -0-                            
               1993        12,076       -0-            -0-                            
               1994        -0-          $2,363         $2,021                         
               1995        -0-          -0-              185                          
               Petitioner sought and received advice from various advisers            
          and agricultural experts.  One such adviser was Jose Collado                
          (Collado), a certified public accountant licensed to practice in            
          the State of California.  Before providing accounting services              
          for petitioner, Collado had provided accounting services to                 
          almond farmers and cattle ranchers located near the Omega farm              
          activity.  Aside from providing accounting services to Omega,               
          Collado regularly advised petitioner to make improvements to                
          Omega’s existing farm activity and to consider alternative                  
          farming methods in order to lower expenses and increase income.             
          Petitioner was advised to increase the size of Omega’s herd,                
          replace dead or unproductive almond trees, and improve                      
          irrigation.                                                                 
               In addition to the advice Omega received from Collado,                 
          Omega’s bookkeeper arranged meetings with various agricultural              
          experts with whom petitioner would discuss changes to Omega’s               
          existing farm activity and/or alternative farming techniques                
          suitable to Omega’s particular terrain and climate.  Petitioner             
          attended a 1-day olive grower’s convention where he sought advice           






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Last modified: May 25, 2011