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profit within the meaning of section 183.1 We hold that they
did not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Haughton, Louisiana, at the time they
filed the petition.
During the years 1991 through 1996, each petitioner was
employed full time by BellSouth. Petitioner Courtney C. Haun
(Mr. Haun) has worked since 1971 as a telephone service techni-
cian repairing telephone lines and installing new telephone
services.
In March 1991, petitioners purchased approximately 15 acres
of real property in Haughton, Louisiana (Haughton property),
although they did not reside on that property until about a year
after they purchased it.
Prior to moving to the Haughton property, petitioners
resided in a trailer house on about two acres of land on which
there were a small barn and a pipe lot for the couple of horses
that they owned and that Mr. Haun used for, inter alia, roping.
Mr. Haun, a farrier who was trained in blacksmithing around
the early 1990's, has been involved with horses since he was
around nine years old and has competed with them since he was in
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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