Michael G. Bunney - Page 9

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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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