Terry F. and Carol J. Zdun - Page 6

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          income and expenses from the apple orchard activity on Schedule F           
          (Profit or Loss From Farming) and attached the schedule to Form             
          1065.  In 1992 and 1993, petitioners reported the income from the           
          dental practice on Schedule C (Profit or Loss From Business),               
          which was attached to petitioners' Form 1040.3  In 1992,                    
          petitioners transferred the dental practice income from Schedule            
          C to the Form 1065 filed by Twin Creeks Organic Farm, reporting             
          the dental practice income as if it were partnership gross                  
          receipts, and then netted that amount with the apple orchard                
          losses.  In 1993, petitioners transferred the dental practice               
          income from Schedule C to Schedule F, as farm income, and                   
          attached Schedule F to Form 1065.  In 1993 and 1994, petitioners            
          netted the income from the dentistry activity with the apple                
          orchard activity income on Schedule F and reported that net                 
          amount as partnership income on Form 1065.                                  
               Petitioners reported dentistry activity gross receipts and             
          apple orchard activity income and expenses as follows:                      
          Item                      1992           1993           1994                
          Gross receipts:                                                             
          Dentistry                $57,920        $68,400        $67,600              
          Apple orchard            -0-1           1,7002         8502                 
          Expenses incurred:                                                          
          Farm expenses3           ($23,008)      ($56,052)4     ($57,887)4           
          Other expenses           (19,462)5                                          


               3  The record does not show whether petitioners filed a                
          Schedule C (Profit or Loss From Business) with their Form 1040              
          (U.S. Individual Income Tax Return) for 1994.                               




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