- 5 - equipment. The machinery was operated by a small motorcycle battery and could be collapsed and put into a backpack. It cost petitioner about $1,000 to purchase the parts and peripheral devices. Petitioners’ revenue from gold mining activity during the years in issue came from two sources: (1) The sale of the gold itself at various trade shows that petitioner attended once or twice each year, and (2) the fees petitioner charged to people who occasionally accompanied him on guided tours on his weekend mining expeditions. Each source produced about half the total revenue of the gold mining activity during the years in issue. In 1997, petitioner discontinued conducting guided tours of abandoned mines because of the inherent danger of gold mining and his potential liability if someone were to be injured. From that point on, in petitioner’s words, he “zeroed in * * * on the mining and prospecting venture.” Petitioners filed joint Federal income tax returns for the years in issue. With each tax return, they attached a Schedule C for their gold mining activity, which they called Brown Enterprises. On the Schedules C, they reported the following: Income 1996 1997 Gross receipts $350 $525 Less: cost of goods sold 124 125 Gross income 226 400 Expenses Advertising $143 $260 Car and truck expenses 3,574 5,011Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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