- 107 - cattle business could be profitable.67 Petitioner purchased a herd of purebred Brahman cattle from Mr. Partin in or about 1982 or 1983. Most of the cattle were midage to older-age cattle, and a few were 1-2 year-old heifers. Petitioner joined the American Brahman Beef Association and registered a brand. In 1989, petitioner returned the cattle back to Mr. Partin. The market for cattle at this time was not good. When Mr. Partin took the cattle back in 1989, the cattle were in good condition. Mr. Partin sold the cattle off over time. Petitioner owned approximately 25 Ferrari automobiles in 1985 to 1988. He did not sell any of the Ferraris in 1985 through 1988. The Ferraris were damaged by vandals, and petitioner went to a dealer to get the damages repaired. Petitioner also had alternators replaced, carburetors cleaned out, and timing belts changed, etc. Petitioner was a member of the Ferrari Club of America. Petitioner did not maintain separate bank accounts for the orange grove, the cattle, or the Ferraris. Petitioner did not report any business activities relating to the orange grove, the cattle, or the Ferraris on any income tax returns for the relevant tax years. To the extent petitioner did report any 67Mr. Partin testified that “the Brahman business was really good. We had good foreign sales, good domestic sales. And I just told him that I thought it would be a good business for him to get into. He had some land he could put some cattle on.” He also testified that “we were selling our yearling bulls for $1,500 apiece and our heifers for about the same price.”Page: Previous 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 116 Next
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