Robert L. Beck - Page 15

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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              
          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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