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listed on the Schedule F as the proprietor of the farming
activity.
B. Discussion
1. Allocation of Item
Petitioner argues that the farming activity is allocable to
Mr. Rowe because petitioner had little or no involvement in
either the horse activity or the fish activity. However,
respondent contends that the farming activity is still allocable
evenly between petitioner and Mr. Rowe. Respondent relies on the
fact that petitioner’s name is listed on the tax returns for
1987, 1988, and 1989 as a proprietor of the farming activity to
support his contention. Additionally, respondent argues that the
horse activity was a family affair that petitioner participated
in by attending different events.
Petitioner testified that she watched Christopher
participate in horse shows “less than half a dozen times” during
the years in issue. Contrary to respondent’s argument,
petitioner testified that only Christopher was involved in
showing horses during the years in issue and that Elizabeth did
not become involved until later. Mr. Shortino corroborated
petitioner on this point, testifying that Elizabeth did not begin
showing horses until sometime around 1992. Petitioner claims she
did not know the extent of the horse activity, played no role in
the decision to acquire the farm property, and only saw the
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