Richard J. and Melodie D. McKeever - Page 19

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                  During the years at issue, petitioners’ returns were                                 
            prepared by the office of Maurice Joffe, C.P.A.  When the returns                          
            were filed, Mr. Joffe believed them to be correct, based on his                            
            understanding of the facts and the then-applicable law.                                    
                  Petitioners reported gross receipts, including income from                           
            sales of horses reported on Form 4797, Sales of Business                                   
            Property, and Form 6252, Installment Sale Income, from their                               
            horse activity as follows:                                                                 
                          Year                        Gross Receipts                                   
                        1987                                -0-                                        
                        1988                                $520                                       
                        1989                                -0-                                        
                        1990                                -0-                                        
                        1991                                -0-                                        
                        1992                                -0-                                        
                        1993                                818                                        
                        1994                                7,400                                      
                        1995                                7,223                                      
                        1996                          15,843                                           
                        1997                               24,206                                      
                        Total                         $56,010                                          
                  Petitioners reported wage income, Schedule C or Schedule F                           
            business income (loss), and adjusted gross income from 1987, when                          
            petitioners began their horse activity, through 1997, as shown in                          
            the following table:                                                                       

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