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years at issue by the following automobile expenses (disallowed
automobile expenses) claimed in Schedules C of his returns for
those years: (1) All claimed depreciation expenses for those
years and (2) other expenses of $293 claimed for 1990. Peti-
tioner was not aware of the errors relating to the disallowed
automobile expenses that appeared in his returns for the years at
issue and could not have detected them by reviewing those re-
turns.
Based on what petitioner told Mr. McVeigh about his horse
activity and his cattle activity, including that he intended to
buy, train, and sell horses and that he had incurred certain
expenses for various stables and training centers that Mr.
McVeigh believed to be reputable, Mr. McVeigh concurred in
petitioner's conclusion, and he and petitioner jointly decided,
that the gross income, expenses, and loss from petitioner's horse
activity during 1989 and the aggregate income, expenses, and
losses from his horse activity and cattle activity during 1990
and 1991 should be reported in Schedules F of petitioner's
returns for those years and that any loss from those activities
could be used to reduce petitioner's income from other sources
that was reported in those returns.
Schedule F of petitioner's return for each of the years 1988
and 1989, during which petitioner was engaged only in his horse
activity, and not his cattle activity, reflected the following
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