- 6 - 1994 1995 1996 Gross receipts $1,140 $3,895 $336 Cost of goods sold 0 (3,500) 0 Gross profit 1,140 395 336 Show winnings 806 0 0 Gross income 1,946 395 336 Expenses (36,538) (36,628) (38,998) Net profit (Loss) (34,592) (36,233) (38,662) In the statutory notices of deficiency, respondent increased petitioner's taxable income for 1994, 1995, and 1996 by $36,538, $40,128, and $38,998, respectively. Respondent determined that petitioner would be allowed Schedule A miscellaneous itemized deductions for the expenses of her Appaloosa breeding and selling activity to the extent of her gross income, but respondent did not allow any such deductions on the ground that such allowable deductions combined with her other itemized deductions are less than her standard deductions for her respective taxable years. Section 183(a) disallows any deduction attributable to an activity not engaged in for profit, except as provided in section 183(b). Section 183(b)(1) provides that deductions which would be allowable without regard to whether such activity is engaged in for profit are to be allowed. Section 183(b)(2) further provides that deductions which would be allowable only if such activity were engaged in for profit are to be allowed, but only to the extent that the gross income derived from such activity for the taxable year exceeds the deductions allowable under section 183(b)(1). For purposes of section 183, the term "activity not engaged in for profit" means any activity other than one with respect to which deductions are allowable for thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011