-2-
Year Deficiency
1993 $37,804
1994 44,796
1995 49,306
After settlement of some issues, the primary issue remaining
for decision is whether petitioners’ cattle ranch activity
qualifies as a for-profit activity.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
The parties have stipulated some of the facts, which are so
found. When they filed their petition, petitioners resided in
Centrahoma, Oklahoma.
A sharecropper’s son, Harland Stonecipher (petitioner) grew
up on a family ranch in Oklahoma. As a youth, petitioner was
responsible for various chores on the ranch, helping to maintain
and manage it and to care for the few head of cattle raised
there.
Petitioner received a college degree with a major in
education. His first job out of college was as an insurance
agent.
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