Anthony W. Jorgenson and Florence A. Jorgenson - Page 9




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          activities on the four properties (collectively, the Melrose,               
          Chireno, and Colorado ranches and the Kerrville farm are referred           
          to as the four properties).  Also, petitioners failed to maintain           
          logs or journals with regard to their participation in the                  
          activities on the four properties.  Petitioners, however, did               
          consult with local government conservation agencies about how               
          best to restore and improve the four properties.                            
               Throughout their ownership of the four properties,                     
          petitioners reported losses.  Specifically, for the years 1986 to           
          1994, petitioners incurred losses (excluding depreciation                   
          deductions) totaling $1,284,349.  As for the years in issue,                
          petitioners claimed the following losses with regard to the                 
          ranching and farming activities:                                            

                                        Ranching and Farming                          
                    Taxable Year        Losses                                        
                    1992                  $122,893                                    
                    1993                205,331                                       
                    1994                261,469                                       

          Rental Properties                                                           
               In February 1992, petitioners purchased the St. John rental            
          property for $375,000.  In December 1992, petitioners transferred           
          a one-half interest in the St. John rental property to the                  
          Jorgenson Family Credit Shelter Trust (the Trust).  On their 1994           
          tax return, petitioners reported $149,230 in expenses with regard           
          to the St. John rental property on Schedule E.  On the notice of            
          deficiency, respondent determined that petitioners and the Trust            




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