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evidence in the record, we are not sure what to make of this
rather terse explanation.
Petitioners’ 1993 Schedule F, Profit or Loss From Farming,
reports no income from crops for 1993 but states on line 34:
“NOTE: CROP SOLD 1/94-NOT Included In Income-CASH Basis TP”. At
trial, petitioner’s testimony about his farm activities was vague,
confusing, and evasive. Petitioner did testify, eventually, that
“I did not raise a crop * * * in ‘93 on that land.”
3. Property Management Use
The Schedule E reconstruction includes as “real estate
property management” expenses of petitioner’s Kentucky property
travel expenses (including airfare) for a trip to Florida in 1993
for both petitioners. The stated purpose of the trip was for them
to bid for vacant property suitable for residential real estate
development. Petitioners submitted copies of credit card receipts
and airline ticket receipts as substantiation for their expenses.
Although the trip took place between February 7 and 12, 1993, the
copy of the airline ticket receipt that petitioner entered into
evidence shows that it was not issued until December 27, 1993.
Mrs. Reynolds’ ticket was issued for travel on January 30 and 31,
1993.9
9 Petitioner’s residential real estate development activity
generated, at best, startup or preopening expenses. See sec.
195(c)(1). Startup or preopening expenses are not deductible
(continued...)
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