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Conclusion
Based on the foregoing, we conclude that petitioners have
failed to show error in respondent’s determination that their
show horse activities in 1993 and 1994 were “not engaged in for
profit” within the meaning of section 183(a).8
II. Mileage Deductions
The second issue is whether petitioners are entitled to
automobile mileage deductions in excess of the amounts determined
by respondent. In 1993 and 1994, Dr. Hillman deducted automobile
mileage expenses for his medical practice in the respective
amounts of $6,823 and $8,128 based on 24,368 miles at 28 cents
per mile in 1993 and 28,027 miles at 29 cents per mile in 1994.
Respondent determined that Dr. Hillman’s allowable mileage
expense deduction is limited to $3,636 (or 12,987 miles) and
$4,308 (or 14,854 miles) for 1993 and 1994, respectively, on the
grounds that petitioners failed to show that any greater amounts
were for an ordinary and necessary business expense or were
expended for the purpose designated.9
8 Accordingly, we do not reach respondent’s alternative
contention that such activities constitute a “passive activity”
within the meaning of sec. 469.
9 Respondent makes no claim that these deductions are
limited by virtue of sec. 274(d). Because we conclude that
petitioners have failed to prove error in respondent’s
determination under sec. 162(a), we need not address the
application of sec. 274(d) in this case.
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