- 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