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               in determining whether a particular activity is engaged                
               in for profit or in applying section 183. * * *                        
               Falling Water Way is at the center of petitioner’s                     
          horse activity.  Her horses are kept on the property and are                
          bred, fed, and watered there.  Petitioner testified that she                
          trains her horses in the arena at Falling Water Way.                        
          However, Falling Water Way also includes petitioner’s four-                 
          bedroom house and a garage unrelated to her horse activity.                 
          With the exception of the house and the garage, we conclude                 
          that Falling Water Way is a part of petitioner’s horse                      
          activity.  Therefore, any appreciation attributable to the                  
          horse facilities and land at Falling Water Way may be taken                 
          into consideration when determining whether petitioner                      
          engaged in her horse activity for a profit.                                 
               Gavilan Hills is approximately 5 miles from Falling                    
          Water Way.  Even though petitioner has not made significant                 
          improvements to the property since 1991, petitioner used                    
          Gavilan Hills to exercise and train her horses throughout                   
          the years in issue.  Gavilan Hills was not used for any                     
          purpose unrelated to petitioner’s horse activity.  We                       
          conclude that Gavilan Hills is a part of petitioner’s horse                 
          activity.  Therefore, any appreciation of Gavilan Hills may                 
          be taken into consideration when determining whether                        
          petitioner engaged in her horse activity for a profit.                      
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