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Tax Regs. The fact that a taxpayer reports a deduction on his
income tax return is not sufficient to substantiate the deduction
claimed on the return. Wilkinson v. Commissioner, 71 T.C. 633,
639 (1979); Roberts v. Commissioner, 62 T.C. 834, 837 (1974).
Despite petitioner’s training and experience as an attorney, he
did not have his books and records stipulated into evidence and
did not bring any supporting documentation with him to trial.
The stipulation of facts agreed upon by the parties did not
include necessary objective facts relevant to the issue of
whether petitioner operated his horse activity with a profit
motive.
Instead of introducing objective evidence that he engaged in
his horse activity for profit, petitioner stated that he “chose
to come [before the Court] and tell my story of what I have done
for the past 45 years.” Petitioner testified that he has been
involved in activities relating to cattle and horses for the past
40 or 50 years and has focused on raising and training horses for
about the past 25 years. He was raised on a farm, majored in
animal husbandry in college, and considers himself an expert in
raising and training horses. Consequently, petitioner explained
that he never felt the need to consult with outside experts. He
bought his ranch in Muskogee about 20 years ago and has made
numerous improvements over the years, including constructing both
indoor and outdoor training arenas, three barns, miles of
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