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Respondent determined deficiencies in petitioner's Federal
income taxes for 1994, 1995, and 1996 in the amounts of $8,528,
$8,671, and $8,479, respectively.
The issue for decision is whether petitioner's Appaloosa
horse breeding and selling activity was an activity "not engaged
in for profit" within the meaning of section 183.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioner resided in Portland,
Oregon, on the date the petition was filed in this case.
Petitioner was graduated from Oregon State University with a
degree in psychology. She took courses in accounting, marketing,
finance, advertising, and public speaking. She later earned a
degree in nursing.
Petitioner worked no less than 40 hours per week as a
registered nurse for Oregon Health Sciences University (OHSU)
during the taxable years in issue. She received employee wages
from OHSU during 1994, 1995, and 1996 in the amounts of
$44,123.80, $44,700.50, and $47,904.24, respectively. OHSU is
located five blocks from petitioner's home.
Petitioner devoted around 15 hours per week to a billing
service that she operated for oncology surgeons until the mid-
1990's. Her net income from the billing service for her 1990
through 1995 taxable years was $18,360, $14,553, $13,763,
$10,950, $1,829, and $124, respectively. She completely ceased
this activity during 1995 because the surgeons for whom she
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