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Thereafter, around September 1995, Mr. Haun and Ms. Haun
separated. Since their separation, Mr. Haun has been precluded
by a court order relating to that separation from selling any
community property that he owned with Ms. Haun. As of the time
of the trial in this case, Mr. Haun and Ms. Haun were still
separated, but they were not divorced.
During 1992, petitioners had at least two horses; during
1993, they had approximately four horses; during 1994, they had
between four and six horses; and as of the time of trial herein,
they had five or six horses.
Petitioners electronically filed their U.S. individual
income tax return (return) for each of the years 1991, 1992, and
1993. Petitioners reported the income, expenses, and loss from
the roping horse activity for each of those years in Schedule C
of their return for each such year. Petitioners filed a return
for 1994 and reported the income, expenses, and loss from the
roping horse activity for that year in Schedule F of their 1994
return.
Rafter H filed a U.S. Corporation Income Tax Return (Form
1120) for 1994 and a U.S. Income Tax Return for an S Corporation
(Form 1120S) for each of the years 1995 and 1996. The income,
expenses, and loss for the roping horse activity for each of the
years 1995 and 1996 were reported in the return filed by Rafter H
for each of those years. The respective losses of Rafter H from
the roping horse activity for 1995 and 1996 were reported as S
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