- 4 - barn, and several pastures for raising and training the horses. Petitioner performed most of the work on the ranch. In 1992 and 1993, petitioner spent a considerable amount of time renovating the ranch. Daily activities on the ranch included weed control of the pasture, hauling hay, repairs of the stalls or fences, and other general maintenance work. In addition to the daily chores, petitioner spent time breaking and training young horses on the ranch. During the breeding season, petitioner's main activity was encouraging "live cover" of the horses by leading the stallion to the mare. When petitioner was away on flights for American Airlines, a laborer would come in to feed the horses and clean the stalls. Petitioner sold one horse in 1992 and none in 1993. Petitioner showed his horses in cutting horse competitions; however, he never received any monetary awards from these competitions. Petitioner maintained inadequate records of the horse breeding activity. Petitioner did not record information about the purchases or sales of his horses. Petitioner did not make written forecasts or projections of future income. Additionally, petitioner has never kept a separate checking account or other bank account for the horse breeding activity. Prior to 1995, petitioner did not advertise the horse breeding activity. The horse breeding activity never showed a profit. Petitioner reported gross sales from this activity in the amountsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011