- 36 - 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.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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