Ronald B. and Annette C. Talmage - Page 81




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              In the March 17, 2004, meeting with Agents Rans and Beach,              
         petitioner stated that he owned only the original dwelling on the            
         Rivercliff property and the barn.  On September 9, 2004,                     
         petitioner signed a memorandum of confirmation and agreement with            
         NCPL which stated that the original intention was to own the                 
         Rivercliff property as a 50-50 joint venture between petitioner              
         and NCPL.  After the notices of deficiency were issued,                      
         petitioner’s story further evolved.  He claimed he owned the                 
         Rivercliff property and that the funds transferred to purchase,              
         develop, and operate the property were nontaxable loans.                     
              Petitioner and Kumiko Talmage designed the new home on the              
         Rivercliff property, petitioner developed the property, and                  
         petitioner occupied the property as his primary residence from               
         June 9, 1999, through the date of trial.  Even after the                     
         Rivercliff property was transferred, RFI purportedly hired                   
         petitioners as caretakers for the property, allowing them to                 
         reside in the Rivercliff property’s new multimillion-dollar home             
         and enjoy full use of the property.  Despite all his machinations,           
         from the time petitioner purchased the Rivercliff property, he had           
         full use, control, and benefit of the property.                              
              Petitioner’s explanations to respondent and his testimony at            
         trial with respect to the ownership of the Rivercliff property               
         were inconsistent and implausible and were created for the sole              
         purpose of misleading respondent, and the Court finds that                   







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