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in the activity unless the individual is involved in the day-to-
day management or operations of the activity. The Court is
unable to find from a preponderance of the evidence that
petitioners were involved in the day-to-day management or
operations of their Limousin cattle activity. The Court finds,
therefore, that hours claimed for the activities of "Books" for
Thomas (4 for 1996 and 5 for 1997) and Susan Truskowsky (21.5 and
46), "Wire Xfers/Foreign Drafts" (9 for 1996 and 4.5 for 1997)
for Susan Truskowsky, "Shows and Sales" for Thomas (25 and 29),
and Susan Truskowsky (96 and 69), "Other Travel" for Thomas (2
and 18.5), and Susan Truskowsky (4 and 27.5) and "Farm Purchase"
for Thomas (52 and 36), and Susan Truskowsky(67 and 41), may not
be counted as participation in the cattle activity. Reduced by
the amounts stated, petitioners' participation in their Limousin
cattle activity was in both years less than the 500 hours
required to qualify under test 1 as material participation.
Test 3
The Court finds that although petitioners did not
participate for 500 or more hours, they did participate in the
activity for more than 100 hours during the taxable year. In
order to qualify under Test 3, however, they must also show that
their participation in the activity for the taxable year is not
less than the participation in the activity of any other
individual (including individuals who are not owners of interests
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