- 10 - Petitioners maintained a separate bank account for all of their horse-related expenditures. Dr. Hillman kept all bills and invoices related to the show horse activity in an envelope and would transfer the information every 2 to 4 weeks to a ledger kept for this purpose. In 1993, Dr. Hillman spent no more than 3 hours per month on bookkeeping and management duties with respect to his show horse activity. Petitioners’ accountant, Mr. Adelman, did not have access to any records for petitioners’ show horse activity. Dr. Hillman instead provided Mr. Adelman with a yearend compilation of income and expense figures for the activity for inclusion on their tax returns. Petitioners did not prepare or maintain a written business plan regarding their show horse activity. Dr. Hillman discussed petitioners’ show horse activity with their accountant, but these discussions focused on the tax aspects of the activity. Mileage Deduction Respondent reduced petitioners’ allowable deductions for business mileage that Dr. Hillman claimed with respect to his medical practice from $6,823 to $3,636 for the 1993 taxable year and from $8,128 to $4,308 for the 1994 taxable year. Dr. Hillman maintained office hours 4 to 5 days a week, performed surgery at five hospitals 4 to 5 days per week, and made hospital rounds 5 to 6 days per week. The distance from hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011