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are to the Tax Court Rules of Practice and Procedure, unless
otherwise indicated. References to petitioner are to Sidney Dishal.
After a concession,1the issue for decision is: Whether
petitioners engaged in their horse breeding and horse racing
activities during the years in issue with the objective of making a
profit within the meaning of section 183. We hold they did.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulated facts and the accompanying exhibits are incorporated
herein by this reference. At the time the petition in this case was
filed, petitioners resided in Piedmont, California.
In 1945, petitioner went to work as a fabric salesman in
southern California and was extraordinarily successful in that
pursuit. In 1958, petitioner left his sales job and started a cotton
processing business which manufactured cotton padding used in
furniture and bedding. By his business and management skills,
petitioner made the business unusually profitable. Petitioner
partially retired from that business in 1990 and fully retired from
it by 1992.
Petitioners were engaged in thoroughbred horse breeding and
racing activities during the taxable years 1992, 1993, and 1994.
Petitioners began their horse activities in 1976 with one horse.
1 Respondent conceded that petitioners were not liable for
the accuracy-related penalty pursuant to sec. 6662 (a) for each
of the years in issue.
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