Thomas B. Drummond - Page 40

                                       - 40 -                                         
          to see how those physical problems affected the profitability of            
          petitioner's horse activity for any of the preceding years,                 
          including the years at issue.                                               
               We have considered and reject all of petitioner's other                
          claims and contentions with respect to his horse activity.                  
               Based on our review of the entire record before us, we find            
          that petitioner has failed to establish that during the years at            
          issue his horse activity was an activity engaged in for profit              
          within the meaning of section 183.  Accordingly, we sustain                 
          respondent's determinations that the deductions that petitioner             
          claimed for 1989, 1990, and 1991 relating to his horse activity             
          are limited by section 183(a) and (b).                                      
               Petitioner's Cattle Activity                                           
               During 1990, petitioner, who did not have any formal train-            
          ing as a cattle breeder, purchased for $3,000 a herd of cattle              
          consisting of a bull and four cows with calf.  The cows produced            
          calves during 1990 or 1991 and each year thereafter.  Petitioner            
          kept his cattle on the NLC land.  During the winter months, they            
          consumed approximately five bales of hay that cost about $35 to             
          $50 a bale, and, during the remainder of the year, they consumed            
          the grass on the NLC land.                                                  
               Petitioner kept the calves produced by his cows for six to             
          seven months until they weighed around 250 pounds, at which time            
          he sold them for approximately $250 each.                                   
               During 1991, petitioner received $1,024 from the sale of the           





Page:  Previous  30  31  32  33  34  35  36  37  38  39  40  41  42  43  44  45  46  47  48  49  Next

Last modified: May 25, 2011