Anatomy of a Disaster Under the Internal Revenue Code

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Francine J. Lipman

Abstract

It might have been the howl of whipping winds; or the crackle, snap, pop of sizzling cinders; or the stench of smoke that woke them into the nightmare of 3:00 a.m. on October 26, 2003. They awoke on Wildcat Canyon Road surrounded by their woods and the Cleveland National Forest engulfed in a firestorm. Lonnie and Lori Bellante and their teenage daughters, Melanie and Lindi, raced from their third-generation homestead to the family Ford to escape threatening flames. The heat, registering hundreds of degrees, melted the truck’s tires and set it ablaze. The family surrounded by hundreds of burning trees somehow found a small clearing. Huddled together, they buried their sweaty faces and burned bodies in the dirt and waited. For four incessant hours, the wildfire that consumed everything but their lives, raged around them. Finally, the Bellante family stumbled to their feet, shocked and exhausted they began to grasp the horror that surrounded them. Even though they lost everything, the Bellantes are reminded daily by the absence of eight neighbors how lucky they are to have survived this disaster.

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