- 6 - Petitioner boarded his horses at a local stable and relied extensively on the services of a David Costello (Costello) to maintain and train his horses. The maintenance performed by Costello consisted of typical physical labors associated with horse ownership. Costello is a professional horse trainer and has a national reputation in the cutting horse industry. He owned and operated the stables and training facility used by petitioner during the taxable years at issue. Petitioner began deducting expenses associated with his horse activity in 1979, its year of inception. The following table lists the income, expenses, and losses reported by petitioner during the 12-year period ending with 1992: Year Gross Receipts Expenses Loss 1981 $0 $27,598 $27,598 1982 8,770 41,149 32,379 1983 15,050 49,715 34,665 1984 4,746 33,498 28,752 1985 1,949 33,397 31,448 1986 2,531 36,888 34,357 1987 12,580 72,858 60,278 1988 7,588 46,295 38,707 1989 3,927 37,414 33,487 1990 1,273 33,448 32,175 1991 167 33,438 33,271 1992 3,271 46,460 43,189 ______ _______ _______ Total 61,852 492,158 430,306 Respondent determined that petitioner did not operate his horse activity with the intent of earning a profit and disallowedPage: 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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