- 2 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011