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the roping horse activity (viz. between $65,000 and $70,000) is
belied by evidence in the record showing that the most that was
received over the period 1991 through 1996 from the sale of a
roping horse was $1,000 during 1993.
On the record before us, we find that petitioners have
failed to establish that they intended in good faith that any
expected appreciation in the value of the assets used in the
roping horse activity, when realized, would, together with any
income from that activity, exceed the expenses therefrom.
We have considered and reject all of petitioners' other
claims and contentions with respect to the roping horse activity.
Based on our review of the entire record before us, we find
that petitioners have failed to prove that during the years at
issue the roping horse activity was an activity engaged in for
profit within the meaning of section 183. Accordingly, we
sustain respondent's determinations.
To reflect the foregoing,
Decision will be entered
for respondent.
7(...continued)
roping horse activity, we would have expected Mr. Haun's
recollection about the number of horses used in that activity to
be clear and specific.
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