Michael T. Shane - Page 6

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          miles to his home only to return to the boarding facility 4 or 5            
          hours later in order to perform his morning activities.                     
               Petitioner managed the financial affairs of his horse                  
          activity through his personal checking account.  The management             
          of this dual-purpose account was facilitated by the use of a                
          computer program petitioner had created.  By design, petitioner             
          used this program to distinguish between personal expenditures              
          and expenditures made in furtherance of his horse activity.                 
          Other than his check register, however, petitioner did not                  
          maintain formal financial records relating to his horse activity.           
          Nonetheless, petitioner did keep detailed records regarding the             
          training, care, and pedigree of his horses.                                 
               Petitioner did not maintain his horses for entertainment or            
          other recreational purposes.  Petitioner did not ride his horses,           
          nor did he permit others, except for qualified jockeys, to ride             
          his horses.                                                                 
               For taxable years 1986 through 1991, petitioner incurred the           
          following losses with respect to his horse activity:                        
                         Year            Loss                                         
                         1986      $35,631                                            
                         1987           26,990                                        
                         1988           39,834                                        
                         1989           32,996                                        
                         1990           39,324                                        
                         1991           36,039                                        
          In 1990 and 1991, petitioner used the respective losses of                  
          $39,324 and $36,039 to offset income he received from Baltimore             





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