James L. Sullivan and Dorothy B. Sullivan - Page 10

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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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