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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-
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Last modified: November 10, 2007