Richard E. Cramer - Page 4




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          horse.  Petitioner also utilized the training services of an                
          individual at Dallas, Texas.                                                
               According to petitioner, the income to be expected from                
          paint horses was from breeding.  There were no monetary awards to           
          be had from participating in shows except that favorable ratings            
          for a stud enhanced the breeding fees that could be charged.                
          Petitioner presented no evidence to establish what success or               
          achievements he attained from the participation of his horses in            
          shows.                                                                      
               Petitioner realized no gross income from his horse activity            
          in either 1995 or 1996.  The record does not show what expenses             
          petitioner incurred during 1995.  On his 1996 joint return,                 
          petitioner, on Schedule C, Profit or Loss From Business, claimed            
          expenses totaling $23,280 and a net loss for that amount, all               
          from the horse activity.  For 1997, petitioner reported on                  
          Schedule C a net profit of $829.5  In early 1998, petitioner                
          terminated the activity after his creditors foreclosed on the               
          horses.  Petitioner, at that time, was unemployed and was unable            
          to continue financing the activity.                                         


               5    Petitioner's 1997 Federal income tax return was not               
          offered into evidence, nor were any books and records offered for           
          that year.  Counsel for respondent stated he had obtained a                 
          computer printout of the return, and petitioner reported, for               
          1997, gross receipts of $17,500, expenses of $16,671, and a net             
          profit of $829.  Petitioner did not address the sources or the              
          nature of the gross receipts.                                               





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