- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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