James J. Lencke and Janene B. Lencke - Page 3

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          stipulations of facts, together with attached exhibits, are                 
          incorporated herein by this reference.                                      
               At the time they filed their petition in this case, James J.           
          Lencke and Janene B. Lencke (petitioners) were residents of                 
          Lafayette, Indiana.  They timely filed their joint Federal income           
          tax returns for the taxable years 1990, 1991 and 1992.                      
          Claimed Business Loss Deductions for Model Railroad Activity                
               James J. Lencke (Mr. Lencke) has been collecting model                 
          railroad equipment and memorabilia for over 50 years.  His model            
          railroad collection is elaborately displayed in the basement of             
          his home.  It includes a complete circus with a big top, 12                 
          operating carnival rides, 12 complete circus trains, hundreds of            
          buildings, signals, lights, and figurines, and at least 800                 
          locomotives, 3,000 freight cars, and 2,000 passenger cars.  Mr.             
          Lencke is very knowledgeable about model railroads.                         
              Because Mr. Lencke had become disabled in July 1989, and               
          needed an activity to occupy his mind and his time, petitioners             
          started a model railroad activity, called Red Caboose, operated             
          from their home in 1990.  Both Mr. Lencke and Janene B. Lencke              
          (Mrs. Lencke), participated in the activity during the years in             
          issue, and both were still engaged in the activity at the time              
          this case was tried.                                                        
               Before deciding to begin their operation of Red Caboose,               
          petitioners visited model railroad shows and sought advice from             
          various vendors of model railroad supplies.  Although they                  




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