James M. Goforth and Brenda Goforth - Page 5




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               Over the years, petitioner entered the cattle in various                
          cattle shows, and the cattle won several awards.  Petitioner was             
          proud of the awards and derived personal satisfaction therefrom.             
               Petitioner used petitioners’ personal checking account to               
          pay for ranch expenses.  Petitioner did not maintain a written               
          business plan, a general ledger, or a written budget with respect            
          to the ranch.                                                                
               In order to be profitable, petitioner needed to maintain at             
          least 140 head of cattle on the ranch.  In light of the                      
          topography of the ranch, however, the ranch could only support               
          100 head of cattle.                                                          
               In 1995, petitioner sold most of the cattle, and thereafter             
          petitioner raised only a few head of cattle.  Also in 1995, for              
          the first time, petitioners' ranch income was greater than                   
          expenses, resulting in a profit of $10,454.                                  
               On their 1983 through 1996 joint Federal income tax returns,            
          petitioners reported gross income, expenses, and net income or               
          loss relating to the ranch and income from petitioner’s medical              
          practice and other activities as follows:                                    














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