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Background
Petitioner resided in Cranbury, New Jersey, at the time that
the petition was filed with the Court.
Petitioner is a certified public accountant who operated an
accounting firm during the relevant period of 1990 through 1994.
Also during that period, petitioner was involved in breeding and
showing horses (the horse activity). Petitioner operated the
horse activity as an S corporation under the name Equine
Investment Properties, Inc. (EIP) during 1990 through 1993 and as
a sole proprietorship during 1994.4 Petitioner claimed net
operating losses from the horse activity for 1990 through 1994 in
the amounts of $45,839, $44,222, $36,162, $31,928, and $26,782.
By comparison, petitioner reported gross receipts from the horse
activity for 1990 through 1994 in the amounts of $4,100, $3,881,
$4,635, $67, and $2,702.
4 In addition to EIP, petitioner operated a horse activity
by the name of Bob Tammaro QuarterHorses (BTQH). The record
provides little about this activity. However, respondent’s
revenue agent determined the following about BTQH:
BTQH has operated for most part as a Schedule F
horse breeding and show activity since 1979. However,
for years 1990-1993 taxpayer revised the original
individual returns and changed BTQH from a Schedule F
to a Schedule E-Farm and Horse Leasing activity in
conjunction with EIP.
The revenue agent also found that BTQH had sustained losses
in all years of operation.
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