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$409. After concessions,2 the sole issue for decision is whether
petitioner operated her thoroughbred horse breeding and racing
activities for profit in 1996. We hold that she did not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and accompanying exhibits are
incorporated by this reference. Petitioner resided in Elberon,
New Jersey, at the time she filed the petition.
I. Petitioner
Petitioner was engaged in thoroughbred horse breeding and
racing activities from the early 1980s through 1996, the year at
issue. She acquired her first horse, a riding horse, after she
married her first husband in 1949. At some point before her
second marriage, she acquired a steeplechase horse for showing.
She was first introduced to thoroughbred horses when she operated
her second husband’s unprofitable thoroughbred horse activities
in the 1960s. She began active thoroughbred horse breeding
activities in 1982, and racing activities in 1984.
Petitioner’s herd has varied over the years in quantity and
ratio of breeding horses to racing horses. Petitioner’s 1996
2Petitioner conceded she was not entitled to $7,302 in
charitable contribution deductions because she failed to present
evidence to substantiate the deduction. Petitioner also failed
to present any evidence or arguments regarding the accuracy-
related penalty under sec. 6662(a). This issue is deemed
conceded.
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