Sidney Dishal and Anna Dishal - Page 9

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        Petitioners were very serious about their horse activities                    
        and operated them in a businesslike manner. Petitioners maintained            
        extensive records and kept complete accounts of their expenses from           
        their horse activities for the years in issue. Bonde, petitioners'            
        horse trainer, testified that petitioner checked every piece of               
        paperwork involved with his horses, including medical charts and              
        veterinarian bills. Bonde further testified that petitioner expects           
        a great deal from a trainer, including providing a leading rider to           
        ride his horses.                                                              
        In addition, petitioners had a business plan, which was to                    
        earn money by breeding top horses to run in superior races. This              
        plan was evidenced by petitioner's actions and attempted changes to           
        improve profitability. Petitioner consulted with knowledgeable                
        individuals about horse breeding and began to "breed up" by                   
        upgrading his brood mares and the stallions with which they were              
        bred. This plan has produced foals which have been performing                 
        better at the racetrack. Based on the facts of this case, we find             
        that petitioners conducted their horse activities in a businesslike           
        manner, and this indicates a profit motive. Sec. 1.183-2(b)(1),               
        Income Tax Regs.                                                              
        A taxpayer's expertise, research, and study of an activity,                   
        as well as his consultation with experts, may be indicative of a              
        profit motive. Sec. 1.183-2(b)(2), Income Tax Regs. Petitioners               
        consulted Bonde as the trainer of their racehorses. Bonde has been            
        training horses for 25 years, at the time of trial had approximately 30       
        clients, and trains between 20 and 50 horses at one time. Adams, the          



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