Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 2




                                        - 2 -                                         
          Revenue Code in effect for the years in issue, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               The issue for decision is whether petitioners’ ongoing                 
          horse-boarding activity was a bona fide business activity within            
          the meaning of section 183 during the taxable years in issue.               
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits attached thereto are              
          incorporated herein by this reference.  Petitioners resided in              
          Loveland, Ohio, on the date the petition was filed in this                  
          case.                                                                       
          History of Petitioners’ Horse-Boarding Activity                             
               Petitioners purchased a tract of land in Clermont County,              
          Ohio, in May 1989 for $450,000.  At the time of purchase, the               
          property contained one barn, one indoor horse arena, pastures,              
          and a residence.  Petitioners purchased the property to provide             
          their family, including their two adult children, with ample land           
          and a home where they all could live and enjoy their shared love            
          of horses.  At the time of the purchase, petitioners’ adult                 
          daughter was involved in the horse industry in Memphis,                     
          Tennessee.  Shortly after acquiring the property, petitioners               
          purchased at least one horse, and petitioner wife (Mrs. Rozzano)            
          engaged in a remodeling of the residence.  Petitioners maintained           
          the property as their primary residence between 1989 and 1992.              







Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: November 10, 2007