Richard J. and Melodie D. McKeever - Page 18




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                  Petitioners’ books and records for the years at issue were                           
            adequate to substantiate all expenses claimed on their Federal                             
            income tax returns with respect to their horse activity in those                           
            years.                                                                                     
            Petitioners’ Other Activities                                                              
                  Petitioners owned and operated two other alleged                                     
            businesses:  A dog breeding business and an antiques business.                             
            These ventures generally were not profitable.  Petitioners                                 
            discontinued the dog breeding operation because they purportedly                           
            believed that the horse activity would be more profitable and                              
            because the owner of a quality stud dog moved out of State.  The                           
            antiques operation was discontinued because the shopping mall in                           
            which petitioners had been renting space was leveled for a                                 
            freeway and because Mr. McKeever, who refinished some of the                               
            items himself, was beginning to suffer adverse health effects                              
            because of exposure to the refinishing chemicals.                                          
            Income Tax Returns                                                                         
                  Petitioners timely filed a Form 1040, U.S. Individual                                
            Income Tax Return, for each of the years at issue.  Petitioners                            
            reported income and expenses from their horse activity on either                           
            Schedule C, Profit or Loss from Business, or Schedule F, Profit                            
            or Loss From Farming, for the years 1987 through 1997, inclusive.                          
            Losses from the horse activity over the years 1987 through 1997                            
            totaled $542,751.                                                                          






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