Thomas B. Drummond - Page 36

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               In Schedules F of his returns for 1988 and 1989, petitioner            
          reported no income and losses of $3,648 and $10,253, respec-                
          tively, from his horse activity.  In Schedules F of his returns             
          for 1990 and 1991, petitioner reported aggregate income of $0 and           
          $1,024, respectively, from both his horse and cattle activities             
          and aggregate losses of $7,780 and $19,588, respectively, from              
          both of those activities.26  The aggregate losses that petitioner           
          reported in Schedules F of his returns for 1992 and 1994 from               
          those activities were $28,691 and $37,478, respectively.  The               
          aggregate loss from those activities that he reported in Schedule           
          F of his 1993 return decreased from the prior year to $11,053,              
          presumably because of an unexplained $60,000 income item and an             
          unexplained $29,202 interest expense item for that year.                    
               Petitioner had sufficient income during the years at issue             
          from various sources so as to enable him to maintain a comfort-             
          able standard of living, notwithstanding the losses from his                
          horse activity that he was able to use to reduce his tax liabil-            



          26  Although petitioner did not show separately the respective              
          income, expenses, and losses associated with his horse activity             
          and his cattle activity for 1990 through 1994, the record herein            
          otherwise establishes (1) that the income reflected in Schedules            
          F of petitioner's returns for 1991 through 1994 was solely from             
          his cattle activity except for an unexplained $60,000 income item           
          for 1993 and (2) that petitioner had expenses relating to his               
          cattle activity during 1991 in the amount of $1,024.  Moreover,             
          based on the characterization of certain expenses that petitioner           
          claimed in Schedules F of his 1990, 1992, 1993, and 1994 returns,           
          it appears that at least $1,428, $17,623, $18,561, and $17,845,             
          respectively, of the aggregate expenses claimed therein related             
          to his horse activity.                                                      




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