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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 sustain
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