- 5 - Petitioner has never owned a farm or other real estate. She boards her broodmares and foals at several locations in Oregon and one location in Arizona.3 Petitioner decides which stallions will breed with her broodmares. She chooses trainers for her foals by matching each foal's heritage and aptitude to the trainers' expertise. Petitioner budgets 30 hours per week for her Appaloosa breeding and selling activity and admits that it consumes nearly all of her personal time. She maintains complete records of her expenses in a single entry ledger and places all of her receipts in envelopes categorized by type of expense. The amounts claimed on her returns were derived directly from these records. Petitioner has a separate bank account for her horse breeding and selling activity. The account is in petitioner's name at a bank other than the bank at which she maintains her personal account. Petitioner's broodmares are insured. Although she has enjoyed some success in breeding and selling Appaloosas, petitioner has never realized a profit during any taxable year. She attributes this lack of any profits to problems of the National Appaloosa Horse Club during the 1980's and more recent setbacks with her own broodmares. Petitioner does not ride Appaloosas for recreational purposes. On Schedules C attached to her 1994, 1995, and 1996 Federal income tax returns, petitioner reported the following amounts: 3 One of petitioner's trainers, Rusty Hadden, testified that one of the benefits of training horses in Arizona is the opportunity to show the horses throughout the year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011