Roger G. Cotner and Marlan W. Cotner - Page 3

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          petitioners resided in Grand Haven, Michigan.  Roger G. Cotner              
          is, and was during the year in issue, a practicing attorney.  He            
          has been a member of the bar of this Court since 1982.                      
          References to petitioner are to Marlan W. Cotner.                           
               Petitioners filed a joint Federal income tax return for the            
          year 1990 on or about October 18, 1991.  After completion of                
          respondent's audit and during the preparation of the notice of              
          deficiency, which was issued on August 18, 1994, petitioners                
          submitted to respondent a Form 1040X, Amended U.S. Individual               
          Income Tax Return, dated July 12, 1994.  The Form 1040X contained           
          an amended Schedule D claiming a long-term capital loss.                    
          Roger G. Cotner prepared petitioners' original return as well as            
          the Form 1040X.  Petitioners now concede the adjustments made in            
          the notice of deficiency.  In their petition, however,                      
          petitioners raise the issue of whether they are entitled to the             
          capital loss deduction claimed on their amended return.                     
               During the year in issue petitioner worked as a self-                  
          employed artist and as indicated, Roger G. Cotner was employed as           
          an attorney.  Petitioner has apparently had a lifelong interest             
          in horses and horseback riding.  She began riding horses in the             
          third grade.  She purchased her first horse while she was                   
          attending college as an art major.  Her particular interest is in           
          dressage riding, a form of riding in which the horse is required            
          to execute a variety of precision movements upon command from its           






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