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Year Income Expenses Excess
1987 $0 $299 $299
1988 1,571 8,010 6,439
1989 3,781 17,419 13,638
1990 12,971 44,451 31,480
1991 14,431 39,913 25,482
1992 36,801 42,722 5,921
1993 21,228 41,088 19,860
1994 61,637 54,707 (6,930)
1995 54,312 67,079 12,767
1996 27,106 23,400 (3,706)
233,838 339,088 105,250
Horse Sales
Petitioner realized the following gains and losses from
sales of horses from July 1, 1990, through June 1, 1996:2
Number of Gain
Year Horses Sold (Loss)
1990 3 $14,667
1991 0 --
1992 2 (6,726)
1993 3 21,507
1994 1 5,392
1995 8 177,808
1996 2 97,086
309,734
History of the Schedule F Activity
Beginning in 1985, petitioner entered into an activity with
a friend and co-worker Tom Coughlin (Coughlin). Petitioner and
Coughlin purchased 50 or more acres in Arkansas, improved it,
named it the “C&S Ranch” (the Arkansas ranch), and conducted a
“cow and calf operation” thereon. They also grew and sold fescue
2 The parties have stipulated the displayed data. They have
also stipulated that petitioners reported an additional $7,000 of
proceeds from the sales of horses on the 1992 Schedule F. Since
we cannot determine whether those proceeds represent a gain or a
loss, we shall disregard them in our discussion of gains and
losses realized from sales of horses.
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Last modified: May 25, 2011