- 3 - In 1993, the tax year in issue, petitioner’s home and place of business in Hemet, California, was a small ranch that he had inherited from his father in 1987. Petitioner lived in the main house on the ranch, which also includes a guest house and a separate office building. In 1992, petitioner had retired from a teaching career in Orange, California. During 1993, petitioner continued his prior second career as a writer for profit and did his writing at the ranch, which was both his home and his primary place of business for his writing activity. In 1992, petitioner also began to make the ranch available as a retreat center. Petitioner did not maintain a separate bank account for the retreat activity, which generated $2,336 of gross income for 1993. In addition to the activities in dispute, petitioner also carried on farming activities at the ranch, raising figs and dogs. The farming activities generated $1,325 of gross income and $25,588 of expense deductions, with respect to which respondent made no adjustments. Issue 1. Depreciation in Connection With Writing and Retreat Activities Neither when petitioner inherited the ranch from his father in 1987, nor at any later time, did he attempt to allocate the basis of the ranch between land and buildings or between buildings and furnishings, nor did he claim any deductions withPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011