Frank K. B. Wheeler - Page 15




                                        -15-                                          
               Petitioner owned an avocado farm.  Table 7 shows the gross             
          income and total expenses that petitioner reported on his                   
          Schedules F and the amount of farm income or (loss) that                    
          petitioner reported on the first page of his Forms 1040.                    
                                       Table 7                                        

                                   Schedule F                                         
               Year          Gross income  Total expenses   Form 1040                 
               1985                -0-       $3,749.19      -0-                       
               1986                -0-       1,532.54       -0-                       
               1987                -0-       914.81     ($914.81)                     
               1988           $113.00        1,638.28    (1,525.28)                   
               1989                -0-       5,796.57       -0-                       
               1991                -0-       2,108.88       -0-                       
               1992                -0-       4,002.43       -0-                       
               1993                -0-       956.89         -0-                       
               1994                -0-       3,577.59       -0-                       
               1995                -0-       4,438.50       -0-                       
               1996                N/A       N/A            -0-                       

                    Petitioner prepared his own tax returns for each of the           
               years in issue and for the prior years.  Petitioner’s 1996             
               tax return was prepared by a paid tax return preparer.                 
                        _____________________________________                         
                    Petitioner did not engage in his videotape activity for           
               profit.                                                                
                    Petitioner was negligent with respect to his tax                  
               treatment of his videotape activity; the entire deficiency             
               for each year in issue was due to this negligence.                     








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