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Section references are to the Internal Revenue Code in
effect during the year in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
A. Petitioners
Petitioners lived in Roland, Arkansas, when they filed their
petition. They have five grown children, three through previous
marriages.
Petitioner Elane Berry (Mrs. Berry) spent time on her
grandparents’ farm when she was a child. She bought a horse when
she was 9. When she was 15, she raised a filly born to a mare
that she had bought. She worked full time as an x-ray technician
after she graduated from high school.
Petitioner Fred Berry (Dr. Berry) graduated from Tulane
University Medical School in 1949. He has practiced medicine
since then. Dr. and Mrs. Berry were married in 1972. Dr. Berry
could not work for 2 months in 1985 because he was ill. In 1991,
Dr. Berry cashed in one of his retirement plans and received
about $17,000.
Dr. Berry and his sister inherited some apartment houses,
which his sister managed, and mutual funds, which Dr. Berry
managed. Dr. Berry’s sister began liquidating the apartment
houses around 1991. The amount Dr. Berry received is not stated
in the record. In 1994, Dr. Berry liquidated some of the mutual
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