- 18 - that the startup phase of a horse-breeding activity may be 5 to 10 years. See Engdahl v. Commissioner, 72 T.C. 659, 669 (1979). In 1976, petitioner bought his first parcel of real estate and built a small barn on it. Petitioner has been breeding Arabian horses since 1976.15 One of petitioner’s witnesses wrote a letter dated March 25, 1999, stating that he has known petitioner “through his reputation as a quality breeder for more than twenty years.” Petitioner argues that he lost money due to a depressed market during certain years. However, petitioner incurred consistent losses during the years 1986 through 1997. Those yearly losses ranged from $80,620 to $131,750 per year. Even when we consider the fact that petitioner reported gains from the sale of horses separately on Form 4797, petitioner’s overall horse activities produced large consistent losses during each of the years 1986 through 1997. According to testimony provided by one of petitioner’s witnesses, the market for Arabian horses began to decline dramatically around 1985. Petitioner purchased his 78.5-acre farm in 1986. Petitioner spent substantial amounts of money refurbishing the house in which he lives and improving the 15Petitioner argues that he only “dabbled” in the industry prior to 1986. However, at trial, he could not recall whether a Schedule C, Profit or Loss From Business, relating to horse breeding was prepared with the earlier income tax returns.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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