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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issue for decision is whether petitioners' cattle ranch
activity constituted an activity entered into for profit under
section 183. All references to petitioner in the singular are to
James M. Goforth.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Amarillo, Texas.
From the time he was a child, petitioner grew up on a ranch
and helped raise cattle.
In 1974, after completing medical school, a residency in
pathology, and 2 years as a military doctor, petitioner began to
practice medicine in Amarillo, Texas.
Also in 1974, petitioners purchased 640 acres of ranch land,
located approximately 43 miles from petitioners' residence in
Amarillo and from petitioner’s medical office. On this land
petitioner began to raise Angus-Hereford cattle. From 1974
through 1982, petitioners purchased additional land adjacent to
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