- 3 - In 1975, petitioner purchased a principal residence (the Livermore residence) and approximately 5 acres of land in Livermore, California (the Livermore property) for $52,000. The Livermore residence was approximately 1,000 square feet in size, and there were several small farm structures on the property. Between 1975 and 1988, petitioner made $25,000 in capital improvements to the Livermore residence, and $25,000 in capital improvements to the farm structures. Petitioner's total adjusted basis in the Livermore residence, farm structures, and 5 acres of land was $102,000. While living on the Livermore property, petitioner operated a mobile farrier (horse-shoer) business out his 1984 Dodge pickup truck, which was equipped with a horse-shoeing camper. Although petitioner parked his truck on the property he did not operate the farrier business on the Livermore premises. In 1988, petitioner received gross receipts from his farrier business of $37,088,3 and paid deductible business expenses of $49,542. Petitioner also operated a horse boarding and breeding business on pasture land that he leased from neighbors. At any given time, petitioner boarded approximately 30 horses for clients on the leased premises. In addition, petitioner kept one stallion, approximately 6 brood mares, and 6 colts on the leased premises, which he owned and used in his horse breeding business. Petitioner did not use these horses for personal purposes. 3 Petitioner's gross receipts from this activity are referred to in the notice of deficiency as "Schedule C gross receipts."Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011