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Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Plymouth, Minnesota, at the time
he filed his petition.
During 1993, 1994, and 1995, petitioner worked as an
accountant. During this time, petitioner resided at his family’s
cabin in Clearwater, Minnesota. The cabin was located
approximately 55 miles from his father’s office in Plymouth,
Minnesota. Petitioner’s father was a Certified Public
Accountant, with an accounting firm in Plymouth. Petitioner
traveled to his father’s business office, 11425 Highway 55,
Plymouth, Minnesota, approximately four times each week during
the years in issue. Petitioner met with clients at his father’s
office. Petitioner did not meet with clients at the cabin where
he was living. Petitioner listed the Plymouth office address as
his business address on the Schedules C for the years in issue.
Petitioner became involved in a horse breeding/racing
operation in the 1980s. Petitioner sold his final interest in
the horse breeding/racing operation in 1995. Partnership returns
for the horse breeding/racing operation were not filed for the
1993, 1994, and 1995 taxable years.
Petitioner deducted net operating loss carryforwards from
his horse breeding/racing operation in all 3 years. Respondent
allowed the net operating loss carryforwards to the extent
petitioner showed that he had a basis of $65,486, $47,255, and
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