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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).
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