- 2 - Respondent determined a deficiency in petitioner's 1993 Federal income tax in the amount of $6,426. The issue for decision is whether petitioner is entitled to various deductions claimed on a Schedule C included with her 1993 Federal income tax return. The resolution of this issue depends upon whether, during 1993, petitioner's dog breeding activity constituted a trade or business within the meaning of section 162. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner filed a timely 1993 Federal income tax return. On that return, petitioner computed her taxable income and Federal income tax liability in accordance with the cash receipts and disbursements method of accounting. At the time that the petition was filed, she resided in Omaha, Nebraska. During 1993 petitioner was employed as a building official/inspector by the City of Gross Pointe Woods, Michigan. Her work schedule was somewhat irregular; however, she routinely worked between 40 and 60 hours per week. She received and properly reported wage income in the amount of $40,306 from this employment. As of the date of trial, petitioner had been involved in breeding and showing Pomeranian dogs for over 30 years. Her interest in Pomeranian dogs arose when she was only 10 years old. For Federal income tax purposes, in 1989 she and her former husband began reporting income earned and expenses paid in connection with this activity on Schedules C included with theirPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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