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a 2,000-square-foot house located on that property. The North
83d Avenue property also contained a guest house which adjoined
petitioner’s residence and a swimming pool.
At least five automotive vehicles were used and/or kept at
the North 83d Avenue property, including two pickup trucks and
three automobiles. Neither petitioner nor Ms. Treadaway was able
to drive any of those vehicles during the years at issue.
As of the trial in this case, petitioner had been operating
a tax consulting business (tax consulting business) for approxi-
mately 30 years. As part of that activity, petitioner repre-
sented taxpayers before the Internal Revenue Service. During the
years at issue, petitioner operated the tax consulting business
from a room located in petitioner’s residence.
Ms. Treadaway, who began riding horses when she was about
six years old, started providing horse-training and other horse-
related services around 1929. (We shall refer to those horse-
related services as horse-training activities.) At least during
the years at issue, the horse-training activities were conducted
on the North 83d Avenue property. Ms. Treadaway continued her
riding and the horse-training activities until she was no longer
able to do so because of her deteriorating medical condition,
which included Alzheimer’s disease. As of July 1994, Ms.
Treadaway’s Alzheimer’s disease was in an advanced stage. As a
result of Ms. Treadaway’s medical condition, Ms. Treadaway was
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