Albert C. Johnson - Page 13

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               (a) Cattle Feed                                                        
               Petitioner agrees with respondent's analysis of petitioner's           
          deductible business-related expenses as evidenced by checks.                
               Petitioner purchased cattle feed during the years in issue.            
          He contends that he is entitled to a $6,000 deduction for cash              
          purchases of feed during each of the years in issue.                        
               Petitioner presented two witnesses with regard to the amount           
          of the cattle feed expenses.  One, Hubert Wiles, owner of the R.L.          
          Wiles Feed Mills Store in Tennessee, testified that during the              
          years in issue petitioner paid him a total of at least $1,560 a             
          year for cattle feed (in both cash and check).  The other, Warren           
          Edward Paul Gagner, Jr., owner of G&G Feed and Seed in Dickson,             
          Tennessee, also testified that he sold feed to petitioner during            
          the years in issue.  Mr. Gagner testified that he was unsure as to          
          the specific amount of feed petitioner purchased during the years           
          in issue.                                                                   
               The deductions agreed to by the parties included amounts               
          petitioner paid to Mr. Wiles by check for the years in issue (1990-         
          -$217, 1991--$529.90, 1992--$399.75, and 1993--$204.50), as well as         
          amounts petitioner paid to Mr. Gagner by check (1992--$530.18, and          
          1993--$670.60), but did not include any cash amounts expended for           
          cattle feed.                                                                
               We found the testimony of both Messrs. Wiles and Gagner to be          
          credible.  Based on the record before us, and using our best                

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