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Rey Lew in professional class competitions.
Petitioners ceased insuring their horses in 1982.
Mrs. Sullivan maintained detailed records of their horse-
related activities in 1992 which included the events in which
their horses competed, expenses, and winnings.
Petitioners have reported a loss from their horse-related
activities for every year from 1969 through 1995, except for the
years 1972, 1981, and 1982. The record does not disclose the
magnitude of the losses that occurred from 1969 through 1988.
The income, deductions, and net losses reported by petitioners on
their Schedule C for the years 1989 through 1995 are as follows:
Year Gross Receipts/Income Deductions Net Loss
1989 $22,380.49 $63,306.14 $40,925.65
1990 13,336.31 53,305.36 39,969.05
1991 17,616.87 49,964.14 32,347.27
1992 21,465.62 72,760.23 51,294.61
1993 17,186.27 51,246.78 34,060.51
1994 25,130.04 72,298.66 47,168.62
1995 14,874.82 48,379.64 33,504.82
Petitioners made a profit of $985.05 in 1972, $7,336.07 in 1981,
and $11,742.18 in 1982, for a total profit of $20,063.30 during
the 26 years in which they have been engaged in their horse-
related activities. Petitioners have no plans to discontinue
their horse-related activities.
In the notice of deficiency, respondent determined that
3(...continued)
trainer.
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