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Dr. Beck’s Schedule F Deductions
In taxable years 1993, 1994, and 1995, Dr. Beck claimed
Schedule F losses relating to an alleged horse operation.
Respondent disallowed these losses in their entirety.
Dr. Beck presented no evidence to demonstrate the existence
of any horse activity. He failed to present any records relating
to the alleged horse activity or to otherwise substantiate or
even explain the losses asserted on his returns.8 Moreover, Dr.
Beck did not establish that the alleged horse activity was
conducted with the primary purpose of making a profit.
Dr. Beck has failed to establish that he is entitled to
deduct the claimed Schedule F losses. Consequently, we sustain
respondent’s determinations disallowing the claimed Schedule F
losses.
Net Operating Loss Carryovers
Dr. Beck claimed, and respondent disallowed, substantial net
operating loss carryover deductions for each year in issue.
In the case of net operating loss deductions, as with other
deductions, Dr. Beck bears the burden of proving that he is
entitled to the claimed deductions. See Rule 142(a); United
States v. Olympic Radio & Television, 349 U.S. 232, 235 (1955);
8 In particular, with respect to the losses of $30,000 and
$25,000, claimed in 1993 and 1994, respectively for “ONE DEAD
HORSE”, Dr. Beck established neither the existence nor demise of
any horse.
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