- 3 - to be a horse owner and purchased his first thoroughbred racing horse. He later acquired other horses but never owned more than three horses at any given time. Prior to acquisition of his first horse, petitioner did research as to the cost of maintaining and training a racehorse, the potential revenue that could be made if a horse won a "certain caliber of race", and the rules and regulations of horse racing. Petitioner hired horse trainers and boarded his horses at various race tracks. In 1990, the year at issue, petitioner owned three thoroughbreds. None of these were able to race during 1990 because they were all injured. From 1985 to 1990, horses owned by petitioner won a few minor races. The activity never realized a profit. Following 1990, petitioner continued the activity with no greater degree of success until 1992 or 1993. On his 1990 Federal income tax return, petitioner reported expenses for training and veterinarians of $22,100, no gross income, and a net loss of $22,100 from his horse racing activity. Petitioner reported wage income of $91,423 from Allied. In the notice of deficiency, respondent disallowed the horse racing activity loss, determining the horse racing activity was an activity not engaged in for profit under section 183, and that petitioner had not properly substantiated the claimed expenses. At trial, respondent conceded that the claimed expenses had been substantiated.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011