Roderick P. Strickland and Linda G. Strickland - Page 14




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          Respondent points out that petitioners did not have a detailed              
          written budget or written business plan and that they paid most             
          of the expenses for their horse activity with personal funds.               
               Petitioners kept complete and accurate records on their                
          personal computer.  They could obtain reports from their computer           
          including reports for each horse.  They could identify the amount           
          of their horse income and expenses in their personal checking               
          account.  See Engdahl v. Commissioner, supra at 667 (one checking           
          account for horse activity, a medical practice, and personal                
          matters).                                                                   
               Respondent points out that petitioners’ horse activity books           
          and records were very different from those in the corporation               
          which employed Mr. Strickland.  We think those differences are              
          understandable, among other reasons, because the horse activity             
          was in the early stages during the years in issue.                          
               It is reasonable for a new activity, with very little cash             
          flow or income, to use personal funds.  Petitioners had a                   
          business plan and pursued it consistently, even though it was not           
          written.  See Phillips v. Commissioner, T.C. Memo. 1997-128                 
          (written financial plan not required for 32-horse farm where                
          business plan evidenced by action).  Petitioners conducted their            
          horse activity in a businesslike manner.  Mr. Strickland built as           
          much of the facilities as possible, and petitioner provided                 
          medical and training services to reduce their expenses.  They               






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