Harvey L. Hoover - Page 13

                                       - 13 -                                         
          Supplies                 31          616           179                      
          Milk expense             391         --            --                       
          Custom hire              2,188        1,068         3,476                   
          Depreciation        20,910       14,293        11,986                       
          Rent                --          8,260         9,456                         
          Taxes                      1,929        1,857           398                 
          Total               63,381       54,652        155,388                      
               1 The parties have stipulated that respondent determined               
          that petitioner incurred allowable expenses totaling $55,389 in             
          1992.  The $1 overstatement is due to rounding.  For purposes of            
          this opinion, we shall use $55,389 as the amount of petitioner’s            
          1992 allowable expenses.                                                    
          Capital Loss                                                                
               On his 1991 Federal income tax return, petitioner claimed a            
          $31,000 loss.  On Form 4797, Sales of Business Property,                    
          petitioner reported that the farm was sold for $75,000 on January           
          20, 1991.  Form 4797 also shows that petitioner’s basis in the              
          farm property was $106,000.  Respondent disallowed the claimed              
          loss and increased petitioner’s taxable income by $31,000.10                
          Investigation                                                               
               Petitioner did not submit any books or records to                      
          respondent’s agents during the course of the examination of his             
          income tax returns.  During the examination, respondent requested           
          the production of certain documents regarding an investigation of           
          petitioner from Ms. Shirley Harrell, an H&R Block employee.                 
          Petitioner contacted Ms. Harrell after she received the request             




               10 Respondent’s notice of deficiency shows this item as an             
          increase in income with no explanation.                                     




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