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claim, the Court granted petitioner leave to file a second
amended petition in which he was to set forth the specific error
or errors in respondent’s determinations and the facts upon which
petitioner bases each assignment of error.
On June 13, 2000, petitioner filed a second amended
petition. In the second amended petition, petitioner’s only
assignment of error is that he is in the business of tree farming
on the parcel of land he purchased in 1994, and that he should be
allowed to deduct expenses incurred in connection with his tree-
farm activity.
Background
Petitioner worked for the California Department of Forestry
(CDF) for 25 years as an analyst, specializing in fire prevention
and wildfire studies. Sometime prior to August 1994, petitioner
conducted a “prepurchase economic and market feasibility study”
on a 39.2-acre parcel of forestland near Whitmore, California.
Petitioner conducted the study for the purpose of ascertaining
the commercial viability of the land. In addition, prior to
August 1994, the CDF made several visits to the property to
survey the existing and prospective forest health and related
entomology, pest control, and wildfire hazard and risk control
issues. In August 1994, petitioner purchased the 39.2-acre
parcel with the intent to start a tree-farming business. The
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