- 15 -
that we determine for 1994 and 1995.10 See sec. 6013(d)(3).
We shall now turn to the determinations in the notice that
remain at issue. With respect to the claimed expenses that were
deducted in Schedules F of the joint returns for 1994 and 1995,
on the record before us, we find that petitioner has failed to
establish that those claimed expenses (1) were paid during those
years, except for expenses totaling $10,101.37 that we have found
were paid during 1995;11 (2) were paid for the purposes specified
in those schedules, except for expenses totaling $10,101.37 that
we have found were paid during 1995 for feed, veterinary care,
horse supplies, and sawdust;12 and (3) constitute ordinary and
necessary business expenses under section 162(a). On the instant
record, we further find that petitioner has failed to show that
the horse-training activities constitute an activity engaged in
for profit within the meaning of section 183.
Based on our examination of the record in this case, we
sustain, except to the extent stated below, respondent’s determi-
10Petitioner does not contend that he is entitled to inno-
cent spouse relief.
11Respondent concedes on brief that $5,306 was paid during
1995 with respect to the horse-training activities. However,
respondent’s concession fails to take into account additional
expenses totaling $4,795.37 with respect to the horse-training
activities that documentary evidence prepared by respondent’s
revenue agent who testified at trial showed, and we have found,
were paid during 1995.
12See supra note 11.
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