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reported the following:
Farm income, sales of livestock $152,059
Depreciation (247,842)
Interest expense (8,830)
“1994 Sharecropboard Exp” (121,647)
“Expense for the cost basis of
purchased cattle that died” (76,558)
Net farm profit or (loss) (302,818)
With respect to the depreciation deduction, petitioner attached a
depreciation schedule reporting a cost basis in his “registured
[sic] cattle” of $880,423. Petitioner subtracted his net farm
loss of $302,818 from wage and interest income totaling $72,942
for total negative income of $229,876. Petitioner reported zero
taxable income and zero tax due. Petitioner reported taxes
withheld of $11,773 and requested a refund of that amount, which
respondent issued.
In December 1995, petitioner also filed a Form 1045 seeking
to carry back to 1991, 1992, and 1993 net operating losses of
$231,952 realized in 1994. As a result of the carryback,
petitioner reported decreases in tax of $10,662, $9,035, and
5(...continued)
Schedules F as if he were directly involved in the farming
activity.
Respondent issued to petitioner a notice of final
partnership administrative adjustment (FPAA) with respect to his
partnership interest in DGE. In a motion to dismiss for lack of
jurisdiction, petitioner argued that this Court lacked
jurisdiction over the Schedule F items because they were
partnership items or affected items, referring to the FPAA.
Petitioner’s motion was denied because the Court concluded that
the Schedule F items were not partnership items or affected
items.
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