- 10 - ranch manager of Rancho del Charro, where petitioners board their horses, supervised approximately 200 racehorses, of which 23 belonged to petitioners. Prior to coming to Rancho del Charro in 1992, Adams worked for 20 years for another horse breeder. Petitioner spent a substantial amount of time consulting and conversing with both Bonde and Adams regarding his horse activities. Petitioner's consultation with experts indicates a profit motive. Petitioner is retired from his cotton processing business and is therefore able to devote a substantial amount of time to the horse activities. Petitioner personally visits the facilities where his horses are boarded and trained in order to inspect, the condition of the horses and to consult with the caretakers and trainers. Including the time spent driving between his home and the boarding facilities, petitioner spends at least 4 hours a day, 6 days a week; inspecting his horses and consulting with their trainers. Bonde, petitioners' horse. trainer, testified "[Petitioner] is very active. He's there very regularly, probably more than most of the clients I train for, actually. I don't ever remember him missing a race, and he comes out and inspects his horses at least five times a week." Adams, petitioners' ranch manager, testified that petitioner spends much time with his horses and that petitioner "examines all of his horses and feeds some of them, doctors them, cleans water troughs, [and] picks up rocks." The substantial amount of time and effort expended by petitioner in the horse activities indicates a profit motive. Sec. 1.183-2(b)(3), Income Tax Regs. A record of substantial losses over several years may be indicative of the absence of a profit motive. Sec. 1.1832(b)(6),Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011