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close family friend. Carl began living with petitioner when he
was 11 months old. Carl was not petitioner’s adopted child.
During 1998, Carl was about 11 years old and lived with his
grandmother. Carl visited petitioner during 1998 on weekends,
holidays, and on his summer break from school.
A. Anchor Inn
During the taxable years at issue, petitioner operated a
fish camp named the Anchor Inn. Petitioner purchased the Anchor
Inn from her mother in or around 1990. The Anchor Inn is
approximately 1.7 acres in size and is located on Lake Kerr. The
Anchor Inn has six rental units and a boat ramp. Each rental
unit has one bedroom and one bath.
The majority of petitioner’s rentals were from February to
May each year. Rentals were generally short-term, typically for
the day or weekend. Petitioner rented each unit for
approximately $30 to $35 per night. Guests were not charged for
use of the Anchor Inn’s boat ramp. Petitioner requested a
minimal cash fee from nonguests for use of the boat ramp.
In or around 1993, petitioner purchased the land and two
houses adjacent to the Anchor Inn from her mother. During the
taxable years at issue, petitioner and her mother resided
separately in the two houses.
B. Horse Breeding Activity
During the years at issue, petitioner operated a horse
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