Melissa S. Spranger - Page 2




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               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 their            

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