Roderick P. Strickland and Linda G. Strickland - Page 15




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          increased their number of horses from one in 1993 to 11 in 1996,            
          and boarded other people’s horses.                                          
                    b.    Investigating How To Conduct the Activity                   
               Respondent contends that petitioners did not investigate the           
          profit potential of their horse activity before they started it.            
          We disagree.  Petitioner has been involved with horses all of her           
          life, and she knows the associated costs.  Petitioners knew that            
          interest in horses was rapidly growing in their area.  Mr.                  
          Strickland had an extensive business background and was familiar            
          with horses.  We believe that petitioners understood the profit             
          potential.  A taxpayer need not conduct a formal marketing study            
          to have a profit objective.  See Burger v. Commissioner, 809 F.2d           
          355, 359 n.6 (7th Cir. 1987), affg. T.C. Memo. 1985-523; Engdahl            
          v. Commissioner, supra at 668.                                              
                    c.    Amy Stenger’s Success at Showing Horses                     
               Respondent contends that petitioners owned ponies when Amy             
          Stenger was young and horses when she was older.  Thus,                     
          respondent contends that petitioners were more interested in                
          providing horses for Amy than in making a profit.  We disagree.             
          Petitioners started their horse activity in 1993 with Tequila               
          Twist and Double A Son Dee Sox, neither of which is a pony.  They           
          bought two mares in 1993, one of which was a quarter pony.                  
               Respondent contends that this case is like Budin v.                    
          Commissioner, T.C. Memo. 1994-185 (taxpayers were more interested           






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