-6-
his harpooning skills. Mr. Lamb has received three laser
treatments on his left eye and two laser treatments on his right
eye in the hope of slowing the progression of diabetic
retinopathy.
For the taxable years 1988 through 1993, the following gross
receipts, expenses, and losses from Mr. Lamb’s tuna fishing
activity are reflected on Schedule C of petitioners’ Federal
income tax returns:
Gross Depreciation Other
Year Receipts Deductions Expenses Losses
1988 $2,460 $15,709 $8,293 1$22,349
1989 2 2 2 2
1990 1,025 20,239 2,649 21,863
1991 -- 14,156 897 15,053
1992 -- 10,111 1,080 11,191
1993 -- 10,204 1,008 11,212
Total $3,485 $70,419 $13,927 $81,668
1The total loss figure is slightly greater than the total of
its components. This discrepancy is unexplained.
2No Schedule C was attached to petitioners’ 1989 Federal
income tax return.
Mr. Lamb did not conduct any commercial tuna fishing after 1993.
Petitioners did not report Mr. Lamb’s tuna fishing as a business
activity on their 1994 income tax return.
Mr. Lamb’s Other Business Ventures
On August 5, 1965, Mr. Lamb incorporated Marriner Lumber Co.
(Marriner Lumber) in Brunswick, Maine. Marriner Lumber’s
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