Roderick P. Strickland and Linda G. Strickland - Page 17




                                       - 17 -                                         
          for profit), affd. 647 F.2d 170 (9th Cir. 1981).                            
               Respondent contends that petitioners’ failure to insure                
          horses they had foaled and horses worth less than $20,000 shows             
          that they lacked a profit objective.  Respondent also contends              
          that petitioners’ failure to charge fees for all riding lessons             
          and hauling leased horses shows they lacked a profit objective.             
          We decline to second-guess petitioners on these points.                     
                    d.    Changing Their Operations                                   
               Boarding horses allowed petitioners to derive income from              
          their facilities before they filled them with their own horses.             
          Respondent concedes that petitioners’ boarding operation is a               
          change contemplated by section 1.183-2(b)(1), Income Tax Regs.,             
          but points out that petitioners’ decision to board horses did not           
          prevent losses.  However, petitioners’ losses would have been               
          larger if they had not boarded horses.  Petitioners also leased             
          horses in 1995 and 1996.                                                    
                    e.    Conclusion                                                  
               Petitioners operated their horse activity in a serious and             
          organized manner.  They considered how best to use their land,              
          the growing interest in horses in their area, and their personal            
          expertise with horses in deciding to start the horse activity.              
          They kept accurate records of their horse activity’s finances and           
          the status of their horses.  They improved and expanded their               
          facilities and boarded horses while beginning to acquire quality            






Page:  Previous  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  Next

Last modified: May 25, 2011