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of monetary significance was recovered during the Goliad
expedition. The few coins that were found by the group were kept
by the owner of the land where the dig took place. Petitioner
maintained contemporaneous handwritten notes of the expenditures
made during the Goliad operation.
In order to get the necessary equipment to and from the work
site, petitioner drove a truck round trip, twice, from Tucson,
Arizona, to Goliad, Texas. Each trip took approximately 23-1/2
hours each way.
During the remainder of 1989, petitioner and Mr. Saldivar
went on occasional treasure hunting trips in Arizona.
Petitioner had wages from his working companies in the
amounts of $50,000, $55,000, and $55,000 for 1987, 1988, and 1989
respectively. Even when he was away from home, petitioner stayed
in touch with his businesses every day by telephone.
Petitioners claimed losses totaling $201,529 in connection
with gold mining and treasure hunting in 1989. Of this amount,
$64,877 was claimed on Schedule E in the form of a distributive
share of a loss of a partnership called the Kruse Group. In
fact, the Kruse Group did not exist as a partnership, and the
loss was reported on Schedule E as the result of an error and was
meant to be placed on Schedule C.6
6 Respondent agreed at trial that all of the losses from
(continued...)
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