- 5 - breeding activity. Petitioner had been raised around, and was familiar with, horses. Prior to starting the horse breeding activity, petitioner consulted horse trainers and breeders about the nature of horse breeding. Petitioner’s objective was to enter horses in “cutting” competitions and then later breed the horses.4 In or around 1995, petitioner purchased her first horse. Later, petitioner purchased a second horse for use in the horse breeding activity. Petitioner hired a professional trainer for the horses. The horses were originally stabled and trained in Georgia, about 265 miles from petitioner’s Florida residence. Petitioner and her children would visit the stable approximately three weekends each month. Petitioner did not prepare a written business plan with respect to her horse breeding activity. Petitioner’s records consisted solely of canceled checks and a few receipts. C. Petitioner’s Income Tax Returns Petitioner filed a Form 1040, U.S. Individual Income Tax Return, for each of the taxable years at issue, and reported her wages from her employment as a paralegal. On her return for each of the taxable years at issue, petitioner identified Carl as either “child” or “son” and claimed a dependency exemption for 4 “Cutting” was described by petitioner as training a horse to “cut” one cow from a herd of cattle.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011