Mary K. Fisher and Charles F. Patterson, et al. - Page 4

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          year 1991, and in the amount of $3,288 for the tax year 1992;6              
          and (6) whether petitioners are entitled to a claimed deduction             
          for office expenses in the amount of $958 for the tax year 1992,            
          attributable to their horse-breeding activity.                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  The stipulation of facts and the attached exhibits are              
          incorporated herein by this reference.  At the time of filing the           
          petitions, petitioners' mailing address was located at Franktown,           
          Virginia.                                                                   
          1.   Petitioner Charles F. Patterson's Net Operating Loss                   
               On his 1991 return, petitioner Charles F. Patterson claimed            
          an NOL carryover, purportedly attributable to the tax years 1988            
          through 1990, in the amount of $113,259.  Upon examination,                 
          respondent disallowed the claimed NOL carryover.  Respondent                
          argues that petitioner has failed to substantiate the loss in               
          question.  The record does not contain petitioner's returns for             
          the tax years 1988 through 1990.                                            


          6  On their respective 1991 returns, petitioners each                       
          claimed depreciation expenses in the amount of $7,255.  After               
          respondent's concession in the amount of $1,405, and each                   
          petitioner's concession in the amount of $900, the amount of                
          depreciation remaining in dispute, with respect to each                     
          petitioner, is $4,950.  On their 1992 return, petitioners claimed           
          depreciation expenses in the amount of $8,166.  After                       
          respondent's concession in the amount of $5,622, petitioners'               
          concession in the amount of $155, and petitioners' claim for                
          additional depreciation in the amount of $899, the amount of                
          depreciation remaining in dispute is $3,288.                                




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