Kenneth E. Perry and Mary A. Hofer - Page 14

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             activity described as "Breeding and showing horses"                      
             beginning with the 1986 tax year.                                        

             Books and Records                                                        
                  Initially, petitioners' financial record keeping                    
             consisted of retaining receipts of expenses related to the               
             horse activity in a box in their home.  At the end of the                
             year, petitioners would sort through these receipts with an              
             accountant to calculate their tax liability.  In or around               
             1988, after the start of respondent's audit, petitioners                 
             began recording receipts and expenditures related to their               
             horse operation on a calendar where they also recorded                   
             important events such as the dates foals were born and the               
             dates of inoculations.  In or around 1989, petitioners also              
             began transferring these records to financial ledgers.                   
             Petitioners did not maintain a separate bank account for                 
             their horserelated activity during any of the years in                   
             issue and did not introduce any of their financial records               
             into evidence.                                                           
                                       OPINION                                        
             Section 183                                                              
                  The primary factual issue in this case is whether                   
             petitioners' horse breeding and boarding operation was an                
             "activity not engaged in for profit" as defined by section               
             183.  Section 183(a) provides generally that in the case of              





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