Robert E. and Carloyn S. Holmes - Page 8

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                                 1987     1988     1989     1990    1991              
             Office -- -- --    (162) --                                              
             Advertising     (13)    --      --      --      --                       
             Net income (loss) (49,678) (64,786) (42,595) (35,372) (14,387)           
             In 1992 and 1993, petitioners incurred net losses from                   
             these activities in the amounts of $12,847 and $14,140,                  
             respectively.                                                            
                  For 1987, 1988, and 1989, petitioners reported the                  
             above losses on Schedules F, Farm Income and Expenses, that              
             are attached to their individual income tax returns for                  
             those years.  For 1990 and 1991, petitioners treated their               
             "farm activities" as having been conducted through a                     
             partnership, R.C. Enterprises (RC), in which each of them                
             held a 50-percent interest.  The partnership reported the                
             income and expenses from petitioners' farm activities on                 
             Schedules F attached to the partnership's returns for 1990               
             and 1991.  Petitioners then reported their distributive                  
             shares of the partnership losses on Schedules E, Income or               
             Loss From Partnership and S Corporation, filed with their                
             individual returns for those years.                                      
                  The following is a discussion of each of the                        
             activities that petitioners undertook in connection with                 
             their land.                                                              










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