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                  Harness Racing                                                                       
                  Petitioner’s testimony regarding harness racing consisted of                         
            the following:                                                                             
                  This horse thing was a matter of--I wanted to grow                                   
                  colts.  I ended up having to pull * * * some horses--                                
                  these were harness horses too, by the way; they’re not                               
                  thoroughbreds.  They’re like the old fairs that people                               
                  used to have.  You might be familiar with the Ohio                                   
                  Fair, which has got the little brown jug, and all the                                
                  farmers would have harness horses that pulled the carts                              
                  to go.  That’s the kind of horses that I had, and                                    
                  started out trying to have a brood mare band and of                                  
                  course, that didn’t fare very well either. * * *                                     
                                                                                                      
                  Other than this testimony, petitioner alluded to the death                           
            of a horse and some insurance payment.  However, in the absence                            
            of any explanation by petitioner elaborating on this, we are                               
            unable to determine what, if anything, this has to do with his                             
            harness-racing activities.  In short, petitioner failed to                                 
            present any evidence that he engaged in the activity for profit.                           
            Furthermore, petitioner also failed to substantiate the claimed                            
            losses.  Accordingly, respondent’s determinations with respect to                          
            petitioner’s claimed “harness-racing” losses for 1990 are                                  
            sustained.                                                                                 
            F.  Capital Gain                                                                           
                  Gains on the sale of property are taxable under section 61,                          
            and the gain is computed by reference to the excess of the amount                          
            realized over the adjusted basis provided in section 1011.  See                            
            sec. 1001.  We must determine whether petitioner reported the                              
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