- 28 -
included in his unreported income in 1992. Fred Hoover did not
issue any of the checks in 1990; therefore, petitioner did not
receive any bartering income in 1990.
We hold that petitioner received and failed to report total
farming income of $168,094.06 in 1990, $119,566.08 in 1991, and
$120,748.89 in 1992.17 The farming income that petitioner failed
to report is itemized as follows:
Source 1990 1991 1992
Best Ever Dairy $137,801.38 $93,768.46 $108,817.49
Jon Hayes 3,455.00 1,375.00 375.00
Ag Max 17,208.11 -- --
Roann 7,680.00 17,500.00 6,200.00
Rochester Sale Barn 679.85 1,606.55 4,677.45
Stony Pike 12,722.72 11,340.75 10,875.20
Fred Hoover-- -- 5,569.32 7,598.75
bartering
Fred Hoover--rent 10,500.00 2,475.00 2,475.00
Total farm income 190,047.06 133,635.08 141,018.89
Less reported 21,953.00 14,069.00 20,270.00
ordinary farm income
Total unreported 168,094.06 119,566.08 120,748.89
farm income
B. Interest Income
On brief, petitioner argues that he did not receive interest
income. The stipulation of facts and the attached exhibits show
that petitioner received interest income of $3,840 in 1990,18
17 Respondent concedes that the following amounts of the
unreported farm income from the sale of breeding stock to the
Rochester Sale Barn and Stony Pike should be given capital gains
treatment: $13,402.57 in 1990, $12,947.30 in 1991, and
$15,552.65 in 1992.
18 The stipulation of facts states that petitioner received
interest income totaling $3,979 in 1990. This appears to be a
mathematical error.
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