Harold W. and Julia A. Kahla - Page 10




                                       - 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 an             






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