- 15 - Petitioners’ expert, Diane O’Connor (O’Connor), appraised petitioners’ Arabian horses in April 1998. At that time, petitioners had the following amounts of unrealized appreciation in the horses they owned or that were born to horses they owned during the years in issue: Cash Foal Total 1998 1998 Horse basis right cost Value Appreciation Pryncz $200 none $200 $5,000 $4,800 Prince Hilal 500 none 500 4,500 4,000 Brigitta La Brisa 2,000 $3,000 5,000 20,000 15,000 Vendalita 2,000 3,000 5,000 25,000 20,000 Splendante 3,000 none 3,000 28,000 25,000 That’s Amore none 6,000 6,000 30,000 24,000 Brilliant none none 0 5,000 5,000 Spanish Ballerina none none 0 10,000 10,000 Total 107,800 OPINION A. Whether Petitioners Operated Their Arabian Show Horse Breeding Activity for Profit The issue for decision is whether petitioners operated their Arabian show horse breeding activity for profit in 1994, 1995, and 1996. A taxpayer conducts an activity for profit if he or she does so with an actual and honest profit objective. See Osteen v. Commissioner, 62 F.3d 356, 358 (11th Cir. 1995), affg. in part and revg. on other issues T.C. Memo. 1993-519; Surloff v. Commissioner, 81 T.C. 210, 233 (1983); Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without opinion 702 F.2d 1205Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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