Harland and Shirley Stonecipher - Page 2




                                         -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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Last modified: May 25, 2011