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donated to a veterinary school in 1994, was claimed only in 1994.
Pal Joey was owned throughout the period but never claimed.
Petitioners took depreciation deductions with respect to the
horses claimed as part of their show horse activity.
For 1993 and 1994, the years in issue, petitioners made no
allocation of their claimed Schedule C expenses for feed and
bedding and stable help between the horses they claimed as part
of their show horse activity and the other horses that they
owned.
Petitioners purchased Riskybiznis, a stallion, in 1988 for
$7,200. The horse was gelded (neutered) in 1991 or 1992,
rendering him incapable of breeding. Petitioners claimed
Riskybiznis as part of their show horse activity in 1991, 1992,
1993, 1994, 1995, and 1996. Riskybiznis participated in the
following horse shows:
Name or Prize money
location Years earned Expenses
Gold Cup 1991/1992 Unknown $1,495
River Ridge 1991 Unknown 792
Silver Cup 1991/1992 Unknown 846
Penn-Ohio 1990/1991 Unknown 932
Jubilee 1990 Unknown 386
Totals Unknown 4,451
In 1996, petitioners “leased” Riskybiznis to a trainer, an
arrangement under which the trainer bore the costs of the horse’s
upkeep in exchange for the right to enter him in horse show
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Last modified: May 25, 2011