Thomas B. Drummond - Page 19

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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-               
               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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