- 8 - Wildlife Department on how to manage and feed herds of deer. Additionally, petitioner had aerial surveys made of roaming deer herds in order to observe the herds’ development. Petitioners’ son, Byron, was employed full time to manage their deer operations; his salary was paid by United.5 Petitioner initially planned to conduct guided trophy hunting expeditions on the South Ranch. Petitioner estimated that when fully operational, these hunts would generate a net income stream of $38,600 per year. During the years in issue, petitioner had not begun conducting these guided hunting expeditions on the South Ranch because of the lack of trophy bucks on the property. According to petitioner, it takes on average 4-1/2 years from the beginning of a breeding program for a fawn to develop into a mature trophy buck. Petitioners’ General Financing and Accounting Practices Petitioners’ cattle-raising and deer operations are leveraged. At the time of trial, petitioners owed between $130,000 and $150,000 of debt incurred in operating both ranches. During the years in issue, petitioners did not maintain 5 During the years in issue, Byron Kahla was paid the following amounts by United: 1992 $33,837 1993 226,969 1994 205,825 Petitioners did not claim Byron Kahla’s salary as a Schedule F expense.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011