George R. and Barbara H. Burrus - Page 7

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          Property contained approximately 274 acres, comprising three                
          tracts acquired by petitioners between 1966 and 1977.  Two houses           
          were located on the Robertson Property for which petitioners                
          received rental income during the years in issue.  The Cheatham             
          Property also had a house from which petitioners received rental            
          income.  The Sumner Property consisted of two tracts, acquired              
          from Dr. Burrus’s mother between 1975 and 1983: an approximately            
          51-acre tract held by the Cardiovascular Surgery Associates, P.C.           
          Money Purchase Pension Trust4 and an approximately 10-acre tract            
          held by petitioners personally.  Petitioners’ residence during              
          the years in issue was located in Nashville, although there was a           
          one-bedroom apartment affixed to a barn on the Cheatham Property            
          where petitioners or family members occasionally stayed                     
          overnight.                                                                  
               The Cheatham Property was purchased by FBHR in 1980 for                
          $606,000, and sold to Dr. Burrus in late 1989 for an effective              
          price of $1,636,106.  Appraisals obtained by petitioners for                
          purposes of trial estimated the Robertson Property’s value at               


               3(...continued)                                                        
          leasing houses on the Robertson Property.  On their returns,                
          petitioners reported the results of these activities separately             
          from the results of FBHR.  Petitioners reported net losses from             
          the farming and rental activities undertaken on these properties            
          in those years.                                                             
               4 At some point in time, petitioners apparently transferred            
          this tract to Dr. Burrus’s sec. 401(k) plan.                                




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