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In 2002, proceeds received from the sale of Lady and Trouble
were deposited into one of petitioner’s personal checking
accounts, not into the Nora Ellen Keating Stony Creek Arabians
bank account.
Petitioner recorded horse activity expenses on a ledger by
category and retained receipts relating to her horse activity in
a folder by month of transaction. Petitioner kept records of
training, ovulatory cycles, and vaccinations relating to each
horse.
Petitioner did not associate her horse activity expenses
with individual horses.
During the years in issue, petitioner did not prepare or
have prepared a written business plan or financial projections
relating to her horse activity.
For 1996 through 2000, petitioners timely filed joint
Federal income tax returns, and for 2001 and 2002 petitioner
timely filed an individual Federal income tax return.
Petitioners’ joint Federal income tax returns for 1996
through 2000 and petitioner’s individual Federal income tax
returns for 2001 and 2002 included a Schedule F, Profit or Loss
From Farming, on which it was indicated that the principal
activity was “horses”.
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Last modified: November 10, 2007