Leonard O. Scales - Page 2

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               Respondent determined deficiencies in petitioner's 1990 and            
          1991 Federal income taxes in the amounts of $4,841 and $5,088,              
          respectively.                                                               
               After a concession2, the sole issue for decision is whether            
          petitioner is entitled to deduct expenses from engaging in                  
          ranching activities during the taxable years 1990 and 1991.                 
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  At the time the petition in this case            
          was filed, petitioner resided in Houston, Texas.                            
          Background                                                                  
               Petitioner has been employed by the U.S. Postal Service for            
          the past 25 years.  During the years at issue, petitioner worked,           
          on average, 45 hours per week, with normal work hours being 4:00            
          a.m. until 12:30 p.m.  Petitioner's annual salary was                       
          approximately $35,000.  Petitioner has a bachelor's degree in               
          political science and has done work towards a master's degree in            
          city planning.                                                              
               At all relevant times, petitioner has been engaged in the              
          activity of raising and tending approximately 40 head of cattle             
          at a ranch he and his two sisters inherited from their father in            
          1977.  Located in Washington County, Texas, approximately 70                
          miles from petitioner's residence in Houston, the ranch consists            

               2Respondent concedes that petitioner is entitled to a                  
          dependency-exemption deduction for his mother for the tax years             
          1990 and 1991.                                                              



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