Harland and Shirley Stonecipher - Page 9




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          $750,000 and that the equipment, vehicles, and bulldozer on the             
          ranch had a market value of approximately $335,000.                         
               Petitioners have never realized a profit from their cattle             
          ranch activity.  On their joint Federal income tax returns for              
          1993, 1994, and 1995, petitioners claimed ordinary expense                  
          deductions relating to the cattle ranch activity, and they                  
          claimed depreciation deductions relating to a house, a cabin, a             
          mobile home, and other improvements and equipment located and               
          used on the ranch.  The schedule below reflects the gross                   
          receipts, expenses, depreciation, and net losses relating to                
          petitioners’ cattle ranch activity that were reported on                    
          petitioners’ joint Federal income tax returns for 1983 through              
          1997:                                                                       

























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