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Petitioners had income from the boarding or stabling of horses of
$150 and $250 for the taxable years 1991 and 1993, respectively.
No income from boarding or stabling was received for 1992.
The Dodges performed most of the work on the farm. A
typical day's work included feeding the horses, putting them out
to pasture, cleaning the stalls and the barn area, and returning
them to the barn in the evening for a final feeding. Mr. Dodge
was in Cincinnati during the week; therefore, Mrs. Dodge and
Andrea often split the work between them. In addition to the
everyday chores, petitioners would spend time grooming their
horses in preparation for shows.
The records kept by petitioners with regard to their horse-
breeding activity consisted of canceled checks, invoices, and an
itemized list of income and expenses for tax purposes.
Petitioners had a single checking account for their horse-
breeding activity and personal expenses. No balance sheets were
prepared for their horse-breeding activity, nor were financial or
break-even analyses prepared or maintained. In addition,
petitioners did not maintain individual expenditures for each
horse. Petitioners did not separate the expenses incurred from
their horse-breeding activity from those incurred for raising
steers.
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