Steven F. and Kathryn A. Dawson - Page 14

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          breeding and training business indicates a lack of profit                   
          objective.  We conclude, however, that this factor is outweighed            
          by the other factors considered above.                                      
               Having considered the factors listed in section 1.183-2(b),            
          Income Tax Regs., all contentions presented by the parties, and             
          the facts and circumstances of this case, we hold that                      
          petitioners actually and honestly intended to make a profit in              
          the Activity.  Consequently, section 183 does not limit the                 
          deductions claimed by petitioners with respect to the Activity.             
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          

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