James L. Christian - Page 3




                                        - 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 with             





Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011