Michael T. Shane - Page 2

                                        - 2 -                                         
               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.                                                              




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011