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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.
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