- 2 -
stated, section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure. Dollar amounts are
rounded to the nearest dollar. James C. Vallette and Arleen R.
Vallette are referred to as Mr. Vallette and Mrs. Vallette,
respectively.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
These facts and the exhibits submitted therewith are incorporated
herein by this reference. Petitioners resided in Sulphur,
Louisiana, when they petitioned the Court. They filed 1989 and
1990 Forms 1040, U.S. Individual Income Tax Return, using the
filing status of “Married filing joint return”. Losses from a
self-owned cattle breeding activity were reported on petitioners'
1989 and 1990 Schedules F, Farm Income and Expenses.
In 1979, petitioners began their breeding activity under the
name Vallette Farm, at a site located approximately 1 to 2 miles
from their home.1 They bred heifers with bulls to produce calves
(a “cow-calf operation”). They sold the bull calves at market,
and they either sold the heifer calves at market or retained the
heifer calves for future breeding. Before 1979, petitioners had
never owned or operated a cattle breeding business. Petitioners
1 During the subject years, this site included 800 acres of
land. Petitioners owned 110 acres of this land, and they leased
the remaining acreage on a yearly basis. Petitioners never
improved any of the leased land.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011