J. Michael and Susan Reimer - Page 17




                                       - 16 -                                         
          The record does not contain a copy of the envelope in which                 
          petitioners mailed their 1995 return.                                       
               On petitioners’ Federal income tax returns for 1993, 1994,             
          and 1995, petitioners deducted Schedule F expenses of $22,665,              
          $38,738, and $25,162, respectively.  Petitioners also deducted              
          Schedule C expenses of $1,072 and $1,365 for tax years 1993 and             
          1994, respectively.                                                         
               In a notice of deficiency for the 1993, 1994, and 1995                 
          taxable years, respondent determined that petitioners did not               
          engage in their horse breeding activity or their NSA water and              
          air filtration activity with an actual and honest objective of              
          making a profit, and that the expenses incurred in connection               
          with each respective activity were therefore deductible only to             
          the extent of income earned from that activity.  Respondent                 
          further determined that petitioners are liable for accuracy-                
          related penalties for all years in issue, and additions to tax              
          for failure to timely file their 1994 and 1995 returns.                     
          K.   Discussion                                                             
               Section 162 allows deductions for ordinary and necessary               
          expenses paid or incurred in carrying on a trade or business.  To           
          be engaged in a trade or business, “the taxpayer must be involved           
          in the activity with continuity and regularity and * * * the                
          taxpayer’s primary purpose for engaging in the activity must be             
          for income or profit.”  Commissioner v. Groetzinger, 480 U.S. 23,           







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