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Except for some minor items, all of the Schedule F expenses
claimed by petitioners were incurred in connection with their
horses. For example, in 1991, petitioners deducted over $1,800
for the cost of veterinarian's fees and medicine, tickets to the
rodeo association, horse magazine subscriptions, and other horse-
related items. In 1992, petitioners deducted over $13,000 in
connection with their horses, a substantial portion of which
included the cost of constructing a horse training arena, which
petitioners' daughter used for riding practice.
Petitioner completed the equivalent of 3 years of college.
Before engaging in TSI and TSR, petitioner was a police officer
for 17 years in the City of Oakland, retiring as a sergeant in
1982. After retiring from the police force, petitioner worked as
a Chief Special Investigator for World Airlines, where he
remained for 2 years.
For the years in issue, petitioner owned two vans, a pickup
truck, and a Porsche.
OPINION
Issue 1. Schedule A Education Expenses
Respondent determined that for 1991 and 1992, petitioners
are not entitled to deduct job-related education expenses,
including mileage, parking, meals, lodging, and other
miscellaneous expenditures claimed by Mrs. Whalley in excess of
the amounts conceded by respondent, because petitioners have
failed to meet the requirements of sections 162 and 274 and the
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