Thomas B. Drummond - Page 51

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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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