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(horse activity) for profit under section 183 in 1995 and 1996.
We hold that they did.
Section references are to the Internal Revenue Code in
effect during the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure. References to petitioner
are to Linda Strickland.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in Morgantown, Indiana, when they filed
their petition.
1. Linda Strickland
Petitioner was raised on a farm in Morgan County, Indiana,
where her family bred and boarded horses. Her father gave her a
horse when she was about 8 years old. She cared for that horse
and showed it in the local 4-H club and saddle club shows. She
trained registered Appaloosa horses for neighbors when she was a
teenager around the early 1960's.
Petitioner bought a registered quarter horse mare in 1969
when she was about 23 years old. Petitioner bred a few quarter
horse mares to a stallion she owned in the early 1970's. She
raised, showed, and sold a few foals around that time. She
competed at several horse shows in Indiana and nearby States.
Petitioner is the mother of Scott Waltz and Amy Stenger.
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