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From 1993 through 2000, petitioner reported the following
gross receipts and losses with respect to the horse-related
activity:
Year Gross Income Expenses (Loss)
1993 ($11,000) $14,380 ($25,380)
1994 (10,350) 40,797 (51,147)
1995 (2,125) 104,738 (106,863)
1996 -0- 80,332 (80,332)
1997 (9,000) 82,065 (91,065)
1998 1,000 62,972 (61,972)
1999 2,900 94,474 (91,574)
2000 13,700 106,550 (92,850)
Total ($14,875) $586,308 ($601,183)
Petitioner has never realized a profit from the horse activity.
Petitioner filed Form 4868, Application for Automatic
Extension of Time to File U.S. Individual Income Tax Return, for
1998, extending the due date for the return until August 15,
1999. Petitioner did not request a further extension of time to
file. On August 26, 1999, petitioner filed his return for 1998.
OPINION
At the outset, we note that petitioner’s briefs did not
comply with Rule 151(e) in that his proposed findings of fact
recite testimony from trial and rely on documents that were not
admitted into evidence. Thus his briefs are unreliable and
unhelpful. The factual assertions not based on evidence will be
disregarded.
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