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years in issue. Petitioners’ 1990 return was due, including
extensions, on October 15, 1991, and was received on October 28,
1991. Petitioners’ returns for the remaining years in issue were
timely filed.
Petitioner George R. Burrus (Dr. Burrus) is a licensed
physician. Petitioner Barbara H. Burrus (Mrs. Burrus) reported
an occupation of “real estate manager” on the returns for the
years in issue.
Dr. Burrus has been involved with farming, cattle, and other
agricultural activities since his childhood. He had check-
writing authority for his father’s farm, starting as a teenager,
and his active involvement continued on weekends and during the
summer while attending college. Dr. Burrus has no formal
education or training in animal husbandry, farming, or similar
agricultural activity.
During the years in issue, Dr. Burrus maintained a
successful medical practice and was chief of his department at a
local hospital where he also served as the chief perfusionist.
He often worked as many as 7 days a week, for as many as 10 to 12
hours per day. During the years in issue Dr. Burrus reported
income from his medical practice in amounts ranging from $233,749
to $691,281.
From 1969 to 1971, Dr. Burrus served as a missionary doctor
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