Thomas B. Drummond - Page 13

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          train some of his horses, including Gator.                                  
               At no time did petitioner retain the services of anyone to             
          appraise the fair market value of his horses.  Petitioner did not           
          project during the years at issue, or at any other time, the                
          future income, expenses, or profits that he expected would be               
          generated by his horse activity.                                            
               Petitioner’s Cattle Activity                                           
               Sometime during 1990, petitioner, who did not have any                 
          formal training as a cattle breeder, purchased for $3,000 a herd            
          of cattle consisting of a bull and four cows (cows) with calf.              
          During 1990 or 1991, and each year thereafter, the cows produced            
          calves.  Petitioner kept the bull, cows, and calves (cattle) on             
          the NLC land.  During the winter months, the cattle consumed                
          approximately five bales of hay that cost about $35 to $50 a                
          bale, and, during the remainder of the year, they consumed the              
          grass on the NLC land.                                                      
               Petitioner kept the calves produced by his cows for six to             
          seven months until they weighed around 250 pounds, at which time            
          he sold them for approximately $250 each.                                   
               Petitioner did not project during 1990, or at any other                
          time, the future income, expenses, or profits that he expected              
          would be generated by his cattle activity.                                  










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