- 4 -
boarding. Typically, between 40 percent and 65 percent of the
stalls were rented at any given time. During the taxable years
in issue, petitioners charged in the range of $375 per month for
each horse boarded at Sugar Tree. In addition to the boarded
horses, petitioners kept their own horse and pony in the stables.
However, the last time that petitioners rode either horse was in
1990.
Mr. Rozzano applied his extensive business knowledge and
experience to the activity at Sugar Tree. Using various computer
software programs, he compiled spreadsheets and projected budgets
for the activity. He also performed most of the major upkeep on
Sugar Tree, including mowing the fields, mending horse fences,
mucking stalls, and also feeding horses on those days that he was
present at Sugar Tree. According to Mr. Rozzano, during the time
that petitioners lived away from Sugar Tree (which was
approximately 80 percent of the time of 1999 and some small part
of 2000), he would wake up each Saturday morning, drive
approximately 5-plus hours from West Bloomfield, Michigan, to
Sugar Tree (Loveland, Ohio), spend 6 to 8 hours each day of the
weekend mowing, mucking, and mending, and then get back in his
car late Sunday afternoon and drive 5 hours back to West
Bloomfield. Mr. Rozzano testified that he made this trip every
weekend and holiday until they temporarily moved back to reside
full time at Sugar Tree sometime in 2000.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007