Leonard O. Scales - Page 4

                                        - 4 -                                         
          Depreciation                  6,183               7,058                     
          Feed purchases                2,937               2,277                     
          Insurance                     --                  399                       
          Conservation                  337                --                         
          Interest                      2,876               1,361                     
          Labor                         --                  1,298                     
          Repairs & maintenance         2,790               1,364                     
          Supplies purchased            2,102               1,921                     
          Veterinary fees               143                 --                        
          Taxes                         --                  151                       
          Legal & accounting            125                  --                       
          Total                         20,215               18,817                   

          Petitioner claimed net farm losses in the amounts of $19,147 and            
          $17,617 for the taxable years 1990 and 1991, respectively.3                 
               To date, petitioner has not reported a net profit in any               
          year from his ranching activities.  At trial petitioner explained           
          that some of the losses in prior years were due to the theft or             
          death of some of his herd.  Petitioner produced no records,                 
          however, nor could he recollect the exact number of such thefts             
          or deaths, or the year in which they took place.                            
               Petitioner concedes that he does not use a written budget to           
          control costs.  Furthermore, petitioner concedes that he has                
          never consulted an expert regarding available means by which he             
          could make his efforts profitable.  Petitioner has, however,                
          spoken about his cattle with a veterinarian friend, a lending               

               3Although the taxable year 1989 is not at issue, the parties           
          stipulated that petitioner reported a net loss from his ranching            
          activities that year in the amount of $18,514.  Furthermore, as             
          demonstrated by copies of petitioner's 1987, 1988, 1992, and 1993           
          Federal income tax returns admitted at trial, petitioner reported           
          net losses from his ranching activities those years in the                  
          amounts of $22,691, $15,566, $9,233, and $15,587, respectively.             




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