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Cost of goods
sold and other
Year Revenue cash expenses Depreciation
19891 -0- $113,273 $19,063
1990 -0- 166,786 23,102
1991 -0- 2359,627 241,265
1992 $700 2286,217 241,902
1993 -0- 2400,292 232,829
1994 2,100 2591,704 245,664
1995 2,900 558,142 73,315
1996 -0- 488,521 76,476
1997 32,364 363,923 41,101
1998 126,170 3464,900 393,624
1999 373,566 3322,328 383,960
1For taxable years 1989 and 1990, petitioner’s original
returns were examined, and no change resulted. For those same
years, petitioner filed amended returns that claimed additional
losses from his mining activities. These claims were examined by
respondent and resulted in loss carryforwards allowed in 1991.
2The parties agree that these amounts are deductible unless
disallowed by sec. 183. Respondent does not assert that any of
petitioner’s mining expenses with respect to the taxable years
1991 through 1994 should be disallowed as a result of the
application of sec. 616 or 617.
3Expenses claimed on returns filed on behalf of JEI.
B. Zila Royalties and Stock Options
From 1989 through 1998, petitioner reported royalty income
from Zila as follows:
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