- 5 -
wage income of $229,176 in 1997, $231,587 in 1998, and $276,600
in 1999. Petitioner worked for EMSA Contracting Services, Inc.
(EMSA), during 1997, 1998, and 1999, and for Florida EM-I Medical
Services, Inc. (EM-I), during 1999. He worked 12-hour shifts and
was scheduled to work 12 to 18 shifts each month.
In 1997, petitioner also worked part time as a medical
director for Florida Regional EMS (Florida EMS). In 1998 and
1999, petitioner worked for Health Central (HC).2
During the years in issue, petitioner was married to Janene
Ryan. Petitioner and his wife owned and bred horses.
III. Horse Activity
A. General
The deductibility of a taxpayer’s expenses attributable to
an income-producing activity depends upon whether that activity
was engaged in for profit. See secs. 162, 183, 212. Section 162
provides that a taxpayer who is carrying on a trade or business
may deduct ordinary and necessary expenses incurred in connection
with the operation of the business. Section 212 provides for a
deduction for expenses paid or incurred in connection with an
activity engaged in for the production or collection of income,
or for the management, conservation, or maintenance of property
held for the production of income.
2 The record is unclear regarding the nature of
petitioner’s work at HC.
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