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The sole issue for decision1 is whether petitioner’s
breeding, training, and showing of Arabian horses was an activity
engaged in for profit within the meaning of section 183.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioner resided in
Newbury, Ohio, at the time he filed his petition.
Petitioner has been a practicing radiation oncologist since
1975. As a radiation oncologist, petitioner regularly works
between the hours of 7 or 8 o’clock in the morning to 5 or 6
o’clock in the evening, 5 days a week. He is also on the faculty
of University Hospital and is on call from the hospital
approximately 1 out of 4 to 5 weeks. In addition, petitioner is
on call 24 hours a day, 7 days a week for his own practice.
Petitioner practiced radiation oncology as an employee of
University Radiologists of Cleveland. During the 22 years that
petitioner was employed by University Radiologists, petitioner
served on its board of directors. During the years 1986 through
1The notice of deficiency contains adjustments to
petitioner’s itemized deductions and claimed exemption allowances
for the years in issue. These are computational adjustments
which will be affected by the outcome of the issue to be decided,
and we do not separately address them.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
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