Sidney Dishal and Anna Dishal - Page 10

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        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),              




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