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Respondent alleges that petitioners are claiming a loss of
$920,000, which is the value placed by petitioners on the labor
contributed by Mr. Tonn over the years prior to 1987 for
developing the on-farm energy systems. In response to this
specific allegation, petitioners state that “the value was not
placed by Petitioners. The value was determined by Russell
Associates Appraisal of Alternative Energy equipment”.5 In an
exhibit attached to respondent’s motion, Mr. Tonn states that he
“suffered a loss of approximately $920,000” as a result of the
March 1987 collection activities. Respondent also presented a
document obtained through informal discovery in which respondent
posed the following question: “Please state the total amount of
loss you suffered from the March 27, 1987 seizure”. Petitioners
responded that a “Loss of alternative energy equipment and
appraisal was left with Eric Johnson District Council at 1-5-01
4(...continued)
offset their gross income for the years in issue with a claimed
loss; thus, we find it unnecessary to address it.
5Respondent posed the following question to petitioners
during informal discovery:
3) Please provide a calculation of your basis in
the on-farm energy plant, i.e., your costs and efforts
involved in creating the on-farm energy plant, prior to
the sale to Laurington Corporation and any
substantiating documentation.
In response, petitioners stated that “Russell Associates
Appraisal was left with Eric Johnson of the IRS District
Council’s Office during the January 5, 2001 meeting.”
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