- 9 - Crossings”. Petitioner used separate letterhead and business cards for the horse activity that bore the name “Arabian Crossings”. Mr. Dahart’s name appears on both the letterhead and business cards along with petitioner’s name. Mr. Dahart did not own any interest in petitioner’s horses. Petitioner has not prepared a written business plan for his horse activity, nor has he prepared a written analysis to determine how he could make a profit or what he would have to do to break even. Petitioner has not consulted with persons with expertise regarding the financial aspects of his horse activity. OPINION The sole issue for decision is whether petitioner’s breeding, training, and showing of Arabian horses activity is an activity not engaged in for profit. Section 183(a) provides that if a taxpayer’s activity constitutes an activity not engaged in for profit, expenses arising out of the activity are allowed as deductions only as provided in section 183(b). An “activity not engaged in for profit” is defined in section 183(c) as “any activity other than one with respect to which deductions are allowable for the taxable year under section 162 or under paragraph (1) or (2) of section 212.” Section 162 generally permits the deduction of expenses incurred in a trade or business, and paragraphs (1) and (2) of section 212 generally permit a similar deduction for expenses incurred “for thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011