Dean L. and Cynthia D. Sanders - Page 3




                                        - 3 -                                         

                                  FINDINGS OF FACT                                    
          Introduction                                                                
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with attached exhibits, is incorporated               
          herein by this reference.                                                   
               Petitioners are husband and wife who, at the time the                  
          petition was filed, resided in Bentonville, Arkansas.                       
          Petitioners made joint returns of income for their taxable                  
          (calendar) years 1992 and 1993 (the 1992 and 1993 returns,                  
          respectively).  Hereafter, we shall use the term "petitioner", in           
          the singular, to refer only to petitioner Dean L. Sanders.                  
               During 1992 and 1993, petitioner’s principal source of                 
          income was from his employment as chief executive officer of the            
          Sam’s Club division of Wal-Mart Stores, Inc. (Wal-Mart).  On the            
          1992 and 1993 returns, petitioners reported substantial income              
          from petitioner’s employment by Wal-Mart and from other sources.            
          On those returns, they also reported “net farm losses” of                   
          $213,838 and $269,913, respectively.  Those losses are detailed             
          on Schedules F, Profit or Loss From Farming, attached to the 1992           
          and 1993 returns (the 1992 and 1993 Schedules F, respectively).             
          On the 1992 and 1993 Schedules F, petitioners identify the                  
          principal activity as “cattle & horses”.  We shall refer to the             
          activity giving rise to the losses shown on the 1992 and 1993               
          Schedules F as “the Schedule F activity”.                                   





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