- 2 - Joint Nora Keating’s Year Deficiency Deficiency 1996 $7,784 1997 6,507 1998 18,181 1999 16,191 2000 20,219 2001 $29,066 2002 35,815 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All references to petitioner in the singular are to petitioner Nora Keating. The issue for decision is whether petitioner’s Arabian horse-breeding activity (horse activity) constituted an activity carried on for profit under section 183. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time of filing the petition, petitioners resided in Williston, North Dakota. In 1996, petitioner moved to Williston, North Dakota, began work as an emergency room physician in a local hospital, and purchased a home on a 10-acre farm. Throughout the years in issue, petitioner worked approximately 60 hours a week as a physician--typically two 24-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007