Courtney C. Haun and Rebecca F. Haun - Page 2

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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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