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files, however, are not completely accurate, and some significant
discrepancies and omissions exist in each.
During the course of the 14-year period ending with 1992,
petitioner owned in excess of 30 horses.4 These horses were
either purchased by petitioner or born to horses that he already
owned. In either event, most were eventually sold during this
14-year period, although some died and others were donated to
various people or organizations.
Throughout the entire course of his horse activity,
petitioner never experienced a net profit, although he did
generate some income. Income was generated from several sources,
including prize winnings, foal sales, and stud fees. Expenses
from petitioner's horse activity, however, always exceeded such
income. Boarding and training costs have constituted the
majority of such expenses.
Petitioner rode his horses in the evenings and on weekends.
He also rode his horses at numerous organized cutting horse
events. Although petitioner's spouse had little interest in
horses, petitioner's two children occasionally rode certain
horses for various reasons. On the average, petitioner devoted
10 to 12 hours each week to his horse activity.
4In any one year petitioner owned as few as 2 and as many as
11 horses. Petitioner owned an average of approximately eight
horses per year.
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