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The issues for decision are:
(1) Whether petitioners are entitled to the deductions for
depreciation of farm buildings and drainage tile that they
claimed on Schedules F, Profit or Loss From Farming, for 2001,
2002, and 2003;
(2) whether petitioners are entitled to elect under section
179 to expense in 2002 a portion of the cost of a truck placed in
service in 2001;
(3) whether petitioners are entitled to deductions for
travel expenses they claimed on Schedules F and Schedules E,
Supplemental Income and Loss, for 2001, 2002, and 2003; and
(4) whether petitioners are liable for the accuracy-related
penalty under section 6662(a) for each of the years at issue.
Background
Some of the facts have been stipulated and are so found.
At the time the petition was filed petitioners resided in
Salt Lake City, Utah.
James M. Riley (petitioner) worked as an extracting
metallurgist for the Department of the Interior from 1953 to
1983. Petitioner’s father and grandfathers were cattle feeders.
Petitioner began his cattle feeding activity while he was
employed with the Department of the Interior. He was familiar
with real estate transactions and bought and sold feeder cattle
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