- 51 - 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 peti- tioner'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 each such return. With respect to petitioner's horse activity, the record does not establish whether petitioner fully disclosed to Mr. McVeigh when he pre- pared petitioner's returns for the years at issue all the perti- nent facts that would bear on the question whether petitioner carried on that activity with the requisite profit motive within the meaning of section 183 (e.g., facts relating to (1) the manner in which petitioner carried on those activities, (2) the extent of time or effort that he devoted to those activities, (3) whether he had the expertise necessary to train his horses, (4) whether he consulted with experts about training his horses, and (5) whether he expected his horses to appreciate in value). With respect to petitioner's cattle activity, the record does not establish whether petitioner informed Mr. McVeigh of any of the pertinent facts relating to that activity. On the record before us, we find that petitioner has failed to establish that any reliance by him on Mr. McVeigh with respect to the claimed deductions in petitioner's returns for the years at issue of the losses from his horse activity and cattle activ- ity was reasonable or in good faith. Consequently, we sustainPage: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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