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Throughout the years at issue, petitioner insured Granot
Loma as his second residence. Petitioner also insured all the
recreational vehicles at Granot Loma; i.e., boats, personal
watercraft, and snowmobiles, as his personal property.
Petitioner occasionally discussed investments or other
business matters while at Granot Loma. Petitioner also
entertained family members and friends with whom he did business,
as well as employees, traders, brokers, and other business
associates, at such events as annual employee weekends and trader
weekends.
From time to time, petitioner investigated possible business
uses for Granot Loma. For example, in 1989, petitioner decided
to plant Christmas trees on the property.5 Also, in 1989,
following a vicious winter storm, petitioner engaged a logging
company to remove some storm-damaged trees. Sometime later,
petitioner hired a contractor to conduct a selective timber
harvesting program on a limited trial basis. In approximately
5The Marquette County Soil and Water Conservation District
was consulted to determine the optimum locations for planting the
trees. Petitioner rejected the Conservation District’s first
choice for siting the trees, as he wanted to keep that field
available for a runway. Petitioner ultimately decided to plant
the Christmas trees along the driveway, a site not recommended by
the Conservation District. In the year following their planting,
approximately one-half of the newly planted trees died because
their roots had not been clipped prior to planting. The burden
of digging up the dead trees and replanting was deemed to exceed
any expected benefit, so the Christmas tree operation was
abandoned. None of the Christmas trees planted at Granot Loma
ever generated any income.
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