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