- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011