Eugene J. Phillips and Barbara A. Phillips - Page 18

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          petitioners performed a detailed analysis of each part of their             
          horse activity.                                                             
               Additionally, we disagree with respondent that petitioners'            
          records contain "many expenditures" that are not farm related.              
          All expenses that were not categorized under a heading such as              
          "Labor Hired" or "Feed Purchased" were placed by petitioners                
          under "Other Expenses".  The expenses cited by respondent as not            
          being related to the farm were all categorized as "Other                    
          Expenses".  We are persuaded by Mrs. Phillips' testimony that               
          petitioners' procedure was to include in their farm books                   
          expenses which might be deductible, leaving the determination of            
          deductibility to their accountant.  Although some expenses listed           
          in the farm books were ultimately determined not to be farm                 
          related, petitioners nevertheless categorized all of their                  
          expenses and periodically calculated the category totals.  As to            
          their records on their horses, petitioners maintained records               
          indicating the horses' pedigree and physical condition,                     
          registered many of their Arabian horses with the International              
          Arabian Horse Association, and kept an action plan for each                 
          breeding mare, projecting when she was to come in season and to             
          be bred and to which stallion she was to be bred.  Based on our             
          review of the record, we conclude that petitioners maintained               









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