James L. Sullivan and Dorothy B. Sullivan - Page 2

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          engaged in for profit" within the meaning of section 183.1                  


                                  FINDINGS OF FACT2                                   
               Petitioners were married and filed a joint Federal income              
          tax return for the taxable year 1992.  At the time the petition             
          was filed, they resided in Hockley, Texas.                                  
               Commencing in 1969, petitioners have been involved in                  
          activities that include the breeding, care, showing, and                    
          occasional sale of cutting horses (horse-related activities).               
          Cutting horses are quarter horses that are bred and trained to be           
          ridden into a herd of cattle to separate, or “cut”, one cow from            
          the rest of the herd.  Historically, the use of cutting horses              
          was to remove a cow from a herd for individual handling, such as            
          for medical attention.  However, performing this function has               
          become a sport, and cutting horse competitions are held                     
          throughout the United States where prize money is awarded with              
          respect to horses that are judged best at "cutting".  Horses with           
          records of superior performance at cutting horse competitions               
          appreciate substantially.                                                   


               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               2 Some of the facts have been stipulated and are so found.             
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.                                                   




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