- 9 - meeting. $920,000.00 Alternative Energy Property only.” The response further states that “Loss of IEEI property not part of this claim.” The appraisal by Russell Associates was performed to estimate the value of the prototype farm energy system equipment and technology which was sold to the Alternative Energy entities.6 The appraisal values Mr. Tonn’s labor for the years 1969 through 1983 at $920,250. Petitioners admit that they were not the taxpayers in the alleged seizure activities in March of 1987 and that they are not seeking damages for any property owned by IEEI.7 Petitioners argue that the value of Mr. Tonn’s labor was in the hard assets of the equipment of the Alternative Energy entities. Additionally, petitioners claim that the alleged seizure activities “wrongfully confiscated Tonn’s labor contribution in inventory and equipment” and these activities “destroyed Tonn’s hope for future income from the sales of the seized property and equipment.” Petitioners do not dispute respondent’s factual allegations that (1) petitioners are claiming a loss of $920,000, 6The appraisal valued the equipment components at $175,500 and the research and development investment at $1,258,926. After adjusting for other factors, the appraisal concluded that the value of the prototype equipment was $1,200,000. The appraisal contains a table valuing the labor put into the equipment and then allocating that labor to different components of the equipment. 7Thus, petitioners could not have incurred a loss with respect to any property owned by IEEI. See, e.g., Rink v. Commissioner, 51 T.C. 746, 752-753 (1969).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011