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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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