Robert and Karen O'Connor - Page 5




                                        - 5 -                                         
               Pursuant to the CBR lease, Omega was to furnish any                    
          machinery, equipment, water, fertilizer, chemicals, and labor to            
          plant, grow, and harvest any and all crops.  Omega was also                 
          responsible for all costs and expenses associated with the                  
          raising of livestock, including, but not limited to, fencing                
          construction and maintenance, barn maintenance, road maintenance,           
          and feed costs.  The maximum number of livestock allowed to graze           
          on the property was 200.  Normal repairs were to be absorbed by             
          Omega, but CBR was responsible for major repairs costing more               
          than $2,000.  Omega and CBR entered into a new leasing agreement            
          on May 1, 1995.  Only petitioner signed the new agreement between           
          CBR and Omega as an officer of both CBR and Omega.  The new                 
          agreement was similar to the previous lease with CBR; however,              
          Omega would now pay CBR $3,000 per month for the rental of land             
          and $1,400 per month for the rental of certain mobile homes.  On            
          its income tax returns for 1990 through 1995, Omega reported                
          receipts and net losses from farming activity as follows:                   
                    Year            Receipts           Net Loss                       
                    1990           -0-                 $39,698                        
                    1991           $2,692              163,687                        
                    1992           5,620               191,516                        
                    1993           12,938              148,268                        
                    1994           4,385               155,156                        
                    1995             185                135,239                       
                    Total          25,820              833,564                        
               From 1990 through 1995, Omega’s receipts from its farm                 
          activity consisted of the following components:                             






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