David E. and Cheryl G. Smith - Page 5

                                        - 5 -                                         

          able to begin breeding their dogs in 1990.  They named their                
          activity Dacher Kennel and began advertising in national dog-               
          breeding magazines.  Petitioners paid thousands of dollars                  
          promoting the name of Dacher Kennel.  In addition, they hired               
          professional handlers to show their dogs and to help establish              
          their kennel's reputation.                                                  
               During the taxable years 1990, 1991, and 1992, petitioners             
          maintained approximately three adult dogs at their Los Gatos                
          residence and 15 to 30 additional dogs at outside kennels.  Mr.             
          Smith typically spent 8 to 10 hours per week performing various             
          activities in keeping and caring for the dogs, including                    
          performing basic veterinary procedures.  Mrs. Smith typically               
          spent approximately 12 hours per week caring for the dogs and               
          spent an additional 12 hours per month in promotional activities            
          related to dog breeding and showing.  For the first                         
          3 weeks after puppies were born, petitioners had to be "on call"            
          to care for the puppies 24 hours a day.                                     
               Mr. Smith kept track of expenses and revenues of the dog-              
          breeding activity on his computer.  Petitioners, however, did not           
          keep track of which of their dogs were profitable.  Although Mr.            
          Smith maintained a separate checking account for Dacher Kennels,            
          occasionally he used personal checks to pay for dog-breeding and            
          showing activity expenses.                                                  







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011