Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 12




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          taxpayers carry on the activity; (2) the expertise of the                   
          taxpayers or their advisers; (3) the time and effort expended by            
          the taxpayers in carrying on the activity; (4) the expectation              
          that the assets used in the activity may appreciate in value; (5)           
          the success of the taxpayers in carrying on similar or dissimilar           
          activities; (6) the taxpayers’ history of income or loss with               
          respect to the activity; (7) the amount of occasional profits;              
          (8) the financial status of the taxpayers; and (9) whether                  
          elements of pleasure or recreation are involved.  Golanty v.                
          Commissioner, supra at 426; sec. 1.183-2(b), Income Tax Regs.               
               Based on our consideration of these factors and in the light           
          of the detailed record in this case, we conclude that                       
          petitioners’ horse-boarding activity was carried on as a business           
          within the meaning of sections 162 and 183 during the taxable               
          years at issue.  In reaching this conclusion, we view the                   
          following facts and circumstances as most persuasive:                       
          Manner in Which Taxpayers Carried On the Activity                           
               Respondent contends that the manner in which petitioners               
          conducted their horse-boarding activity does not indicate that              
          the activity was engaged in for profit during the years in issue.           
          The relevant inquiries before us include whether petitioners                
          conducted their business in a manner similar to other comparable            
          businesses, whether petitioners maintained complete and accurate            
          books and records, and whether changes were attempted to improve            







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