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that he was providing. Petitioner and Ms. Treadaway claimed in
Schedules C of the 1994 and 1995 joint returns expenses for legal
and professional services of $13,588 and $13,823, respectively.
Schedule F of each of the joint returns for 1991 through
1995 identified Ms. Treadaway as the proprietor and, except for
the 1995 joint return,3 showed training horses as the activity in
which she was engaged. Schedules F of those joint returns
reported the following income, expenses, and net loss:
Year Income Reported Total Expenses Claimed Net Loss Claimed
1991 $22,285 $72,512 $50,227
1992 24,806 47,328 22,522
1993 25,820 59,805 33,985
1994 27,245 60,100 32,855
1995 32,170 48,036 15,326
Included within the foregoing expenses claimed for 1995 were the
following amounts of expenses paid during that year with respect
to the horse-training activities:
Nature of Expense Amount Paid
Feed $9,351.46
Veterinary expense 200.00
for shoeing horses
Horse supplies 279.91
Sawdust 270.00
Also included within the foregoing expenses claimed for 1994 and
3Schedule F of the 1995 joint return did not identify the
activity in which Ms. Treadaway was engaged.
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