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1991 240 Michael Hoover 125
1992 219 Harvey Hoover 375
Petitioner also sold dairy cattle through Rochester Sale
Barn in 1990, 1991, and 1992. Although Rochester Sale Barn
issued checks to either Tadd Hoover or Michael Hoover, petitioner
received the proceeds from the checks. Petitioner’s gross sales,
expenses, and net sales from Rochester Sale Barn were as follows:
Year Gross Sales Expenses Net Sales
1990 $698.60 $18.75 $679.85
1991 1,643.15 36.60 1,606.55
1992 4,793.80 116.35 4,677.45
Respondent concedes that these amounts should be given capital
gains treatment.
From 1987 through 1992, petitioner also sold livestock
through the Stony Pike Livestock Auction (Stony Pike). Although
Stony Pike issued most of the checks to Tadd Hoover,8 Tadd Hoover
endorsed the checks and then gave them to petitioner. The gross
income, expenses, and net sales with respect to these livestock
sales were as follows:
Year Gross Sales Expenses Net Sales
1990 $13,042.60 $319.88 $12,722.72
1991 11,588.55 247.80 11,340.75
1992 11,113.50 238.30 10,875.20
8 Of the 20 checks in the record, 17 checks were issued to
Tadd Hoover, 2 checks were issued to Michael Hoover, and 1 check
was issued to petitioner.
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