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of 120 acres, 30 of which are used to grow hay, and 90 of which
are used to run and rotate the cattle. Petitioner was born and
raised on a ranch, performing tasks which included plowing
fields, raising and breeding cattle, administering medication via
syringe, and hay harvesting. Petitioner received some formal
education in agriculture while in high school, taking classes in
cattle breeding and raising, fertilization of land, and equipment
repair.
Petitioner customarily travels to the ranch several times
per week in order to perform chores and to tend to the cattle.
Petitioner also spends most weekends at the ranch. Since
inheriting an interest in the ranch, petitioner has spent more
than $25,000 on farm equipment. Petitioner bought this equipment
with the intention of increasing productivity and decreasing the
man hours necessary for work on the ranch.
Although the record is not clear on the matter, it appears
that petitioner began reporting income, deductions, gains, and
losses, with respect to his activities at the ranch on his 1982
Federal income tax return. For the taxable years 1990 and 1991,
the years at issue, petitioner reported Schedule F gross income
from "Raising Cattle" and "General Livestock" in the respective
amounts of $1,068 and $1,200. For those same years, petitioner
claimed Schedule F deductions for the following expenses:
Item 1990 1991
Car and truck $2,722 $2,988
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