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been in the horse business since 1979, and they operated an S
corporation called Showcase Farm, Inc. Mr. Rowe purchased a
horse trailer for the Shortinos to use in connection with the
horse activity. Mr. Rowe and petitioners’ son, Christopher, also
participated in showing horses during the years in issue. For
the years in issue, the income and expenses of the
horse activity were reported on a Schedule F attached to
petitioners’ tax returns.
At some point in time during the years in issue, Mr. Rowe
became involved in raising fish. The income and expenses for the
horse and fish activities (collectively, farming activity) were
combined for tax reporting purposes. Petitioner was not involved
in the fish activity.
For the years in issue, the following losses from the
farming activity were reported on the Schedules F:
Year Loss Amount
1987 $143,650
1988 117,278
1989 139,448
1990 184,221
For the taxable years 1987, 1988, and 1989, petitioner and Mr.
Rowe were listed on the Schedules F as the proprietors of the
farming activity. For the taxable year 1990, Mr. Rowe alone was
21(...continued)
petitioners.
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