- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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