Walter L. Medlin - Page 18

                                       - 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

Last modified: May 25, 2011