Charles and Beatrice M. Reynolds - Page 31




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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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