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Background
Some of the facts have been stipulated and are so found.
Petitioners are husband and wife. They filed a timely 1994 joint
Federal income tax return. At the time the petition was filed,
petitioners resided in Amissville, Virginia. References to
petitioner are to Alma F. Jordan.
During all relevant times, petitioners lived on a
20-acre farm. They constructed a new barn on their farm, or
substantially improved an existing one, during 1994. Petitioners
own several thoroughbred race horses. They acquired their first
race horse in 1986. By 1994 they owned six broodmares that,
except when boarded at a race track during a racing season or
elsewhere for breeding purposes, were kept at their farm. The
horses are not used for recreational riding purposes. At least
two of the horses, Jordan’s Tan and Hilarious Astro, were entered
in various thoroughbred racing events prior to the year in issue.
During 1993 Jordan’s Tan earned purses totaling $6,208 from at
least 12 races at Charles Town Races, in Charles Town, West
Virginia.
Petitioners intend to acquire a stable of race horses by
mating their broodmares with stallions owned by others. Their
plan is to produce foals that, after appropriate training, will
develop into successful thoroughbred race horses. Consequently
and typically, the primary source of income that petitioners
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Last modified: May 25, 2011