- 10 - Petitioners’ 1992-94 Federal Income Tax Returns Petitioners timely filed their 1992, 1993, and 1994 Federal income tax returns. On their returns, petitioners reported income from various sources, as follows: Year Compensation Interest Schedule C United 1992 $97,089 $300,035 $126,500 $45,174 1993 409,596 162,391 --- 235,410 1994 387,786 6,007 --- 224,221 Petitioners offset this income with the following Schedule F losses attributable to their cattle-raising and deer operations: Year Schedule F Net Loss 1992 $211,868 1993 162,454 1994 187,951 OPINION The issue we must decide is one of fact: whether petitioners entered into or carried on their Schedule F activities with an intent to make a profit. If petitioners did not have the requisite profit motive, as respondent maintains, then all deductions exceeding the revenue attributable to those activities would be disallowed pursuant to section 183(a). Respondent contends that petitioners lacked the requisite intent to make a profit in carrying out their Schedule F activities. In support of this position, respondent maintains (1) petitioners failed to carry on the activities in a businesslike manner, (2) the activities generated substantial losses over anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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