Sheila Mae Howard - Page 7

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          him.                                                                        
               Petitioner reported income and expenses from the Anchor Inn            
          on her Federal income tax returns for 1996 through 1998 on                  
          Schedules C as follows:                                                     
                    Gross               Total               Total                     
          Year      Income Reported     Expenses Claimed    Losses Claimed            
          1996      $6,136              $37,215             $31,079                   
          1997           6,045               27,821         21,776                    
          1998           8,586               17,822         9,236                     
               Petitioner reported income and expenses from the horse                 
          breeding activity on her Federal income tax returns for 1996                
          through 1998 on Schedules F, Profit or Loss From Farming, as                
          follows:                                                                    
                    Gross               Total               Total                     
          Year      Income Reported     Expenses Claimed    Losses Claimed            
          1996      $1,901              $11,037             $9,136                    
          1997           1,576               25,109         23,533                    
          1998           2,300               14,997         12,697                    
               D.  The Notice of Deficiency                                           
               In the notice of deficiency, respondent determined that with           
          respect to the Anchor Inn, petitioner had not substantiated                 
          Schedule C expenses for 1996, 1997, and 1998, in excess of                  
          $25,305, $25,023, and $15,490, respectively.  Respondent also               
          determined that petitioner’s horse breeding activity was not an             
          activity engaged in for profit within the meaning of section 183            
          and disallowed all of her Schedule F deductions to the extent               








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