James J. Lencke and Janene B. Lencke - Page 10

                                       - 10 -                                         
          Operating Expenses    (19,620)  (14,990)  (18,474)                          
                              (18,520)  (10,083)  (18,052)                            
          Depreciation          (11,298)   (7,828)   (6,006)                          
          Income/(Loss)         (29,818)  (17,911)  (24,058)                          

               Although petitioners' gross income from their model railroad           
          activity increased to $8,577 in 1993, $16,142 in 1994, and                  
          $14,575 in 1995, their operating expenses substantially                     
          increased, so that their claimed losses were $23,255, $11,656,              
          and $14,443, respectively, for those years.  Thus, the claimed              
          losses for 1990 through 1995 totaled $121,141, and petitioners              
          anticipated no net profit for their model railroad activity in              
          1996.  Since 1993 petitioners' activity has been operated in the            
          name of Jim's House of Trains because they were informed that the           
          name Red Caboose is a trademark.                                            
               In the notice of deficiency respondent determined that                 
          petitioners' model railroad activity was not engaged in for                 
          profit and therefore disallowed the claimed loss deductions.                
          Claimed Nonbusiness Bad Debt Deduction                                      
               On January 30, 1990, petitioners lent Dale and Gloria                  
          Christopher $6,000 to enable them to purchase a flower shop in              
          Monticello, Indiana.  They had known the Christophers for 4 or 5            
          years prior to lending them the $6,000, and they had become                 
          friends through church and other social activities.  At that time           
          both couples lived in Battleground, Indiana, which is a small               
          community with less than 1,000 residents.                                   






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