Dean L. and Cynthia D. Sanders - Page 5




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          The item “Livestock, produce, grains, and products raised” of               
          $7,000 for 1992 is proceeds from the sale of one or more horses.            
          The item “Other income” of $36,801 and $21,228 for 1992 and 1993,           
          respectively, is proceeds (winnings) from horse shows.                      
               During 1992, petitioner sold another two horses (not                   
          reported on the 1992 Schedule F), one at a gain of $534 and one             
          at a loss of $7,260.  During 1993, petitioner sold three horses             
          (not reported on the 1993 Schedule F), all at a gain, for a total           
          gain of $21,507.                                                            
               Schedules F attached to petitioners' joint returns for 1986            
          through 1996 show income, deductions, and losses as follows:                
               Year      Income         Deductions      Loss                          
               1986      $18,282        $54,165        $35,883                        
               1987      225            51,394         51,169                         
               1988      1,571          98,706         97,135                         
               1989      6,539          123,517        116,978                        
               1990      16,494         164,907        148,413                        
               1991      30,107         171,709        141,602                        
               1992      43,801         257,639        213,838                        
               1993      21,228         291,141        269,913                        
               1994      66,137         307,478        241,341                        
               1995      54,312         422,587        368,275                        
               1996      27,106         120,794        93,688                         
                                                                                     
          Each year’s income is composed of one or two categories:  “Sales            
          of livestock, produce, grains, and other products you raised”; or           
          “Other income”.  Petitioners began claiming expenses for horse              
          shows beginning in 1987.  For 1987 through 1996, petitioner’s               
          horse show expenses, gross income reported from horse shows, and            
          the excess (except for 1994 and 1996) of horse show expenses over           
          horse show income were follows:                                             




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