Larry G. and Mary L. Bangs - Page 8

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          category.  There was no record of the lemon farming activity in             
          any of the trust records, but detailed records of petitioners’              
          investment and rental activities were included in the trust                 
          records.  Losses from the lemon farming activity were deducted on           
          a trust return for at least 1999 and 2000, however.                         
               On audit, the revenue agent informed petitioners that the              
          trusts would be collapsed.  Petitioners decided to hire a CPA to            
          prepare pro forma returns so petitioners would be better prepared           
          to settle with respondent.  The pro forma returns aggregated the            
          amounts reported on the trust returns and the amounts reported on           
          individual returns for the years at issue.  Petitioners and the             
          revenue agent were unable, however, to resolve the lemon farming            
          activity issues.                                                            
               During the course of the audit, respondent’s revenue agent             
          asked to tour the property.  Petitioners would not permit the               
          revenue agent to tour the property and would not answer questions           
          about their farming activity.  Respondent issued a summons to               
          petitioners to permit the revenue agent to tour petitioners’                
          property.  When the revenue agent was finally permitted to visit            
          the property, she noted that the trees did not look healthy and             
          that some were dead.  She also noted that the trees on the                  
          property across from petitioners’ property, on the other hand,              
          were healthy and thriving.  The revenue agent also noticed that             
          petitioners were storing yard items in the ripening room and the            
          warehouse storage held several classic cars in various stages of            
          repair.                                                                     





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