Albert C. Johnson - Page 14

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          estimate, we find that petitioner paid an aggregate of $10,000 (by          
          cash and check) for the 4 years in issue for the cattle feed, or an         
          average of $2,500 per year.  See Cohan v. Commissioner, supra;              
          Vanicek v. Commissioner, supra.  The following summarizes the cash          
          payments we believe petitioner made to Messrs. Wiles and Gagner:            
          Cash Payments Made            Cash Payments            Total Cash           
          Year     to Mr. Wiles              Made to Mr. Gagner      Expenses Allowed 
          1990    $1,343.00 (1,560-217)     $940.00 (2,500-1,560)        $2,283.00    
          1991     1,030.10 (1,560-529.90)   940.00 (2,500-1,560)         1,970.10    
          1992     1,160.25 (1,560-399.75)   409.82 (2,500-1,560-530.18)  1,570.07    
          1993     1,355.50 (1,560-204.50)   269.40 (2,500-1,560-670.60)  1,624.90    
                                                                                     
               (b)  Trip to Belgium                                                   
               Petitioner traveled to Belgium in 1990.  Initially, petitioner         
          claimed entitlement to a $2,800 deduction with regard to the trip           
          (consisting of $1,800 in airfare and $1,000 for expenses), which he         
          asserted was business related.   At trial, petitioner admitted that         
          he spent only $800 for the trip.                                            
               Petitioner has failed to produce any evidence to prove that he         
          expended $800 for a 1990 trip to Belgium.  Thus, we hold that he is         
          not entitled to a deduction for a 1990 trip to Belgium.                     
               (c) Barn Depreciation                                                  
               In approximately 1986, petitioner built a 60- by 100-square            
          foot barn to house horses for his 5 children.  Petitioner testified         
          that the barn cost approximately $30,000, and that it was appraised         
          for $69,000.  The barn contained 14 stalls, an office, wash rack,           
          and feed room.  In 1989, when petitioner became interested in the           
          Belgian blue cattle, he converted the barn to house cattle.                 




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