- 2 - the sole issue for decision is whether petitioner's horse breeding activity was an activity not engaged in for profit. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Campbell, Texas, at the time he filed his petition. Petitioner has been an airline pilot with American Airlines for more than 32 years. During 1992 and 1993, petitioner was on reserve status. During this time, he worked an average of 5 days a month, but he was available to work 20 days a month. In 1992 and 1993, petitioner earned wages of $169,858 and $166,040, respectivelyPetitioner has been involved with horses since childhood. He owned his first cutting horse2 when he was 7 years old and first trained a cutting horse when he was a teenager. Starting in 1979, petitioner decided to breed, train, and sell quarter horses for cutting horse competitions (the horse 1(...continued) charitable contributions in the amounts of $5,200 and $4,800 for 1992 and 1993, respectively. Respondent concedes that petitioner is entitled to deduct home mortgage interest expenses in the amounts of $20,376 and $19,882 for 1992 and 1993, respectively, and an unreimbursed employee expense in the amount of $1,216 for 1993. 2 Horses (generally quarter horses) are bred and trained as cutting horses for competitions in which the horse must separate one cow from the herd. Horses are bred with "cutting" bloodlines which give them the natural ability to be competitive. The raising and training of a foal for cutting horse competition takes approximately 4 years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011