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The sole issue for decision is whether petitioner's
horseracing and horse-breeding activity was undertaken with the
objective of making a profit within the meaning of section 1831
during the years at issue. We hold that it was.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein. At the time the petition was filed,
petitioner resided in Towson, Maryland. Petitioner timely filed
Federal income tax returns for taxable years 1990 and 1991.
During the years at issue, petitioner worked as a full-time
computer programmer for Baltimore County, Maryland. In exchange
for his services to Baltimore County, petitioner earned
approximately $35,000 per year. Petitioner also maintained a
part-time job with Maryland Casualty Co. during the years at
issue. In 1990, petitioner worked an average of 20 hours per
week, or a total of 844 hours, for Maryland Casualty Co. In
1991, petitioner worked a total of 111 hours for Maryland
Casualty Co.
During the years at issue, petitioner also was engaged in
the breeding and racing of horses. Petitioner's involvement with
horses dates back to the early 1970's. In the mid-1970's, while
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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