- 17 - 3. The time and effort expended by the taxpayer in carrying on the activity. Respondent argues that petitioner could not have devoted enough time and effort to the horse activity to make it profitable in 1993. As support for this claim, respondent relies on the facts that petitioner maintained her law practice in Huntington Beach, California, during the entire 1993 taxable year and that the driving distance from petitioner’s home in Huntington Beach, California, to the location of her horse activity in Julian, California, is approximately 120 miles. From these facts, respondent argues that petitioner would only have been able to devote any substantial time and effort to her horse activity on an occasional weekend or holiday. Petitioner claims, however, to have spent a significant amount of time conducting her horse activity in 1993. She claims that until June 1993, she spent 4 days per week conducting horse activity in Julian, California. Petitioner also claims that, starting at the end of June 1993, she spent 6 days per week conducting horse activity in Julian, California. Petitioner also testified that she purchased a trailer in 1993, presumably to serve as her residence while conducting horse activity in Julian, California. Petitioner also claims that she began to scale back her law practice during 1993 due to her age, the health of her mother, and the increase in her horse activity. Petitioner offered no corroborating evidence toPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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