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McVeigh, Jr. (Mr. McVeigh), about the sale of the drawing in
question and inquired about establishing some type of retirement
plan. Mr. McVeigh advised petitioner to consult with Earl
Schoenborn about establishing a retirement plan. The three of
them met and discussed the amount of the contribution that
petitioner could make to a retirement plan for 1989 after taking
into account the approximate amount of petitioner's income and
expenses during 1989 from various sources, including the New Life
Center and the sale of the drawing in question.
Sometime thereafter, petitioner chose to consult with
another individual about establishing a retirement plan. Peti-
tioner established a simplified employee pension (SEP) for 1989
to which he contributed $20,000. Petitioner's contributions to
the SEP for 1990 and 1991 were $30,000 and $26,000, respectively.
Petitioner's Horse Activity and Cattle Activity
Petitioner's Horse Activity
During the early 1970's, petitioner, who has at all relevant
times enjoyed equestrian activities, owned a horse, took riding
lessons, and learned how to train a horse (1) to perform at an
unspecified level in dressage and (2) to do low-level jumps,
provided that the horse had received some training in jumping.
In July 1988, petitioner, who did not have any formal
training as a horse breeder or a horse trainer, purchased for
approximately $8,000 a five-year old thoroughbred gelding named
Moonshadow (Moonshadow) that had received some training in riding
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