Joseph E. Machado - Page 11

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                              Net Profit and Losses                                   
                         Allocated From LB Partnership                                
                    Year       To Joseph          To Robert                           
                    1983      ($10,199)           ($10,199)                           
                    1984      (  6,035)           (  6,035)                           
                    1985      5,713               5,713                               
                    1986      (  9,436)           (  9,436)                           
                    1987      (  8,112)           (  8,112)                           
                    1988       ( 15,394)          ( 15,394)                           
                    Total  ($43,463)              ($43,463)                           

          Petitioners' 1988 Tax Returns and Respondent's Audit                        
               Petitioners filed Forms 4868 to extend to August 15, 1989,             
          the time to file their 1988 Federal income tax returns.  On these           
          Forms 4868, petitioners estimated that for 1988 their respective            
          Federal income tax liabilities would be zero.                               
               On August 15, 1989, petitioners filed their respective 1988            
          Federal income tax returns and reported thereon tax liabilities             
          of zero.                                                                    
               With their respective 1988 Federal income tax returns,                 
          petitioners attached separate Schedule C's relating to the above-           
          described horse breeding and horse racing activities.                       
          Petitioners reported on their respective 1988 Federal income tax            
          returns gross income, losses from their horse breeding and horse            
          racing activities, losses from the LB Partnership, and taxable              
          income, as follows:                                                         
                                 Horse   Horse                                        
                                Breeding  Racing                Taxable               
          Petitioners Tax Returns Activity Activity LB Partnership   Income           
          Joseph     $ 99,798   ($35,258) ($17,621)   ($15,394) $18,898               
          Robert*    150,000    ( 35,381) ( 17,749)   ( 15,394) 45,475                





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