- 12 - 1991 for which his financial information was made available to the Court, petitioner reported substantial losses from the horse activity. Petitioner has not introduced evidence of even a single profitable year, although he did offer uncorroborated testimony that he previously sold a cattle ranch at a profit and sold a portion of his current horse ranch in 2001 to a relative at a profit. In contrast to his history of losses from his horse activity, the record shows that petitioner was a successful attorney. For the years in question, petitioner was able to use losses from his horse activity to offset income earned from the practice of law. The magnitude of petitioner’s losses from his horse activity and the substantial tax benefits petitioner received by offsetting those losses against income from his law practice support the view that petitioner did not engage in his horse activity for profit. Petitioner testified that he was an expert in raising and training horses. He grew up on his father’s cattle and horse farm, has a degree in animal husbandry, and has focused on training horses for the past 25 years. Petitioner’s testimony that he is an expert in raising and training horses and that he had no need to consult with advisers about such matters is not contradicted. Petitioner also testified that he spent approximately one-half of his time on his horse activity.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011