- 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.
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