- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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