- 14 - 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 ofPage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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