Andris Zarins and Zigrida A. Zarins - Page 5




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               Petitioner did not seek expert advice about how to operate a           
          tree farm for profit.  Sometime before 1990, he asked neighbors             
          who had botany degrees for advice on how to grow trees.                     
          Petitioner attended several agricultural seminars:  a fish                  
          raising seminar in 1992, evergreen seminars in 1995 and 1997, a             
          tree pruning seminar in 1997, and a nursery short course at Ohio            
          State University in 1998.                                                   
               Petitioners earned an unspecified amount of income from 1984           
          or 1985 to 1990 by allowing people to use their land to hunt and            
          to practice for competitions with their dogs.  Petitioners also             
          tried to grow strawberries and grapes on their land and to raise            
          fish.                                                                       
          C.   Petitioners’ Tax Returns                                               
               Petitioners reported on Schedules F, Profit or Loss From               
          Farming, attached to their tax returns for 1993 to 1998 that they           
          operated a tree farm.  Petitioners reported the following amounts           
          of nonfarm income (i.e., wages, pension, interest, and taxable              


















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