Roderick P. Strickland and Linda G. Strickland - Page 11




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          quarter horses.  He sold some quarter horses to petitioners.                
          Steven Mobley (Mobley), a certified public accountant, prepared             
          petitioners’ income tax returns for 1993 through 1996.  Mobley              
          gave petitioners tax advice for their horse activity.  Alderson             
          and Mobley did not advise petitioners how to make their horse               
          activity profitable.                                                        
               7.   Petitioners’ Personal Pleasure From Their Horse                   
                    Activity                                                          
               Petitioner gets personal pleasure from raising, training,              
          and showing horses.  She enjoys going to horse shows and seeing             
          her horses do well.  Mr. Strickland gets pleasure from                      
          petitioner’s and Amy Stenger’s success with horses and likes to             
          work with the foals.                                                        
          D.   Horse Income and Expenses                                              
               Petitioners reported the following on their Schedules C                
          (Profit and Loss) for their horse activity:                                 
          Income                                                                      
                              1993     1994     1995     1996   Total                 
          Sale of foals                      $1,700              $1,700               
          Boarding                                400  $10,995   11,395               
          Show winnings                 $250      276            526                  
          Riding lessons                160       60             220                  
          Horse leasing                        175    2,280   2,455                   
          Gross income             0     410     2,611   13,275  16,296               
          Expenses                                               Total                
          Depreciation        1,883   7,190    12,790   14,036  35,899                
          Other               7,180  12,887    20,819   29,189  70,075                
          Total expenses       9,063  20,077    33,609   43,225 105,974               
          Net loss            (9,063)(19,667)  (30,998) (29,950) (89,678)             







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