- 10 -
he sold were sold at auction, following the appearance of a horse
in a competition.
Petitioner's Participation in the Schedule F Activity
During 1992 and 1993, petitioner worked an average of 50 to
55 hours a week for Wal-Mart. He spent 15 to 18 hours a week in
connection with the Schedule F activity. On weekends, he also
spent time on his houseboat. Petitioner went bird hunting 8 to
10 days a year.
Petitioners’ Residence
Petitioners resided on the Arkansas ranch, in a house of
approximately 5,700 square feet, containing four bedrooms and
five bathrooms. The house also had a pool and Jacuzzi.
Respondent’s Adjustments
Respondent disallowed the total expenses ($257,639 and
$291,141 for 1992 and 1993, respectively) claimed on the 1992 and
1993 Schedules F.3 Respondent explained his disallowance on the
ground that the Schedule F activity was not engaged in for
profit.
3 Respondent made compensating adjustments to petitioners'
itemized deductions to reflect the deductions allowable under
sec. 183(b). Assuming we sustain respondent’s primary
adjustments, those compensating adjustments are not in question.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011