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fact that the taxpayer failed to pay any Federal withholding tax
for his income from American Airlines, indicate a lack of profit
objective. See Whalley v. Commissioner, T.C. Memo. 1996-533.
Conclusion
After reviewing the entire record, we conclude that
petitioner did not engage in the horse breeding activity with an
actual and honest objective of making a profit within the meaning
of section 183.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011