- 32 - horse operation were a mere hobby, activity for pleasure, or a business founded solely for tax benefits, it would not seem petitioner would entirely abandon the operation." Trafficante v. Commissioner, T.C. Memo. 1990-353. Thus, based on the entire record we find that petitioners, through BPS, operated their horse sales activity with the intent to make a profit. Accordingly, petitioners' related losses for the years in issue are deductible. Issue 4. Whether Gillian Johnston's Horse Training Activity Known as GJ Stables, Conducted at Bendabout Farm, Was an Activity Engaged in For Profit GJ Stables During the years in issue, Gillian Johnston, a licensed steeplechase horse trainer since 1964, operated a steeplechase training and racing activity known as GJ Stables out of a converted cow barn and pasture on approximately 35 acres at Bendabout farm. Gillian Johnston has had one assistant for at least 8 years. Respondent stipulated that petitioners employed competent help to carry on the horse training and racing activities of the stable. Unlike a breeding stable which makes money by selling horses, a racing stable such as GJ makes money primarily by racing its horses to win purses. There is, however, always the possibility that a very successful racing horse may be purchased. In operating the stable, Gillian Johnston consulted with recognized experts in the steeplechase business, including Dr.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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