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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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