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income reported from the sale of calves during the years at
issue.5 Accordingly, petitioner is allowed, under section
183(b)(2), a deduction of expenses each year equal to the gross
income reported.
To reflect the foregoing,
Decision will be entered
under Rule 155.
5It is not clear from the record whether petitioner incurred
items of expense contemplated by sec. 183(b)(1) in either of the
years at issue. As there are sufficient expenses which otherwise
fall under sec. 183(b)(2), however, we are satisfied that
petitioner is entitled to a deduction each year in an amount
equal to the gross income reported from his ranching activities.
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Last modified: May 25, 2011