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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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