George R. and Barbara H. Burrus - Page 13

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               Year       Income1       Expenses2      Profit (Loss)                  
               1996      $29,967         $190,053       ($160,086)                    
               1997       46,890          193,053        (146,163)                    
               1998       61,698          220,154        (158,456)                    
               1999       44,621          210,005        (165,384)                    
               1 In addition to livestock sales, includes tobacco allotment income and income
               from the rental of houses located on the Maple Row properties.  The latter income
               was reported on the “Other income” line of the Schedules F for 1996 to 1999 as
               follows:                                                               
                         Year       Other Income - Schedule F                         
                         1996                     $8,506                              
                         1997                      6,903                              
                         1998                      9,906                              
                         1999                      9,720                              
               2 Includes amounts reported by petitioners on Schedules F for 1996 to 1999 as
               mortgage interest, taxes, depreciation, and conservation expenses as follows:
          Mortgage                                  Conservation                      
          Year    Interest      Taxes     Depreciation        Expenses                
          1996    $56,627      $15,982      $25,233              –-                   
          1997     61,413       11,537       22,939              –-                   
          1998     57,454       12,309       25,860              --                   
          1999     54,861       12,172       27,318            $8,061                 
               Petitioners also owned and operated a shopping center in               
          Sumner County, Tennessee, called “Maple Row Center” (MRC) during            
          the years in issue.  MRC’s several retail spaces were leased to             
          tenants, and day-to-day operations were managed by a property               
          manager.  MRC was nearly breaking even when petitioners purchased           
          it in 1987, and it was operating at a slight profit by the time             
          of trial.                                                                   
               In the notice of deficiency, respondent determined that the            
          farming activities reflected on petitioners’ Schedules F for the            
          years in issue were not activities engaged in for profit and that           
          the reported farm losses therefrom should be disallowed under               






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