Dale Allan Rinehart - Page 2

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          the sole issue for decision is whether petitioner's horse                   
          breeding activity was an activity not engaged in for profit.                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioner resided in               
          Campbell, Texas, at the time he filed his petition.                         
               Petitioner has been an airline pilot with American Airlines            
          for more than 32 years.  During 1992 and 1993, petitioner was on            
          reserve status.  During this time, he worked an average of 5 days           
          a month, but he was available to work 20 days a month.  In 1992             
          and 1993, petitioner earned wages of $169,858 and $166,040,                 
          respectivelyPetitioner has been involved with horses since                  
          childhood.  He owned his first cutting horse2 when he was 7 years           
          old and first trained a cutting horse when he was a teenager.               
               Starting in 1979, petitioner decided to breed, train, and              
          sell quarter horses for cutting horse competitions (the horse               


               1(...continued)                                                        
          charitable contributions in the amounts of $5,200 and $4,800 for            
          1992 and 1993, respectively.  Respondent concedes that petitioner           
          is entitled to deduct home mortgage interest expenses in the                
          amounts of $20,376 and $19,882 for 1992 and 1993, respectively,             
          and an unreimbursed employee expense in the amount of $1,216 for            
          1993.                                                                       
               2  Horses (generally quarter horses) are bred and trained as           
          cutting horses for competitions in which the horse must separate            
          one cow from the herd.  Horses are bred with "cutting" bloodlines           
          which give them the natural ability to be competitive.  The                 
          raising and training of a foal for cutting horse competition                
          takes approximately 4 years.                                                


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