Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 18




                                       - 18 -                                         
          Expertise of and Effort Expended by the Taxpayers                           
               Respondent does not challenge either petitioners’ expertise            
          or the time and effort expended on the activity at issue.  We               
          believe that petitioners have established, through credible                 
          testimony, that they not only were well possessed of the                    
          knowledge necessary to operate a horse-boarding business, but               
          that Mr. Rozzano contributed vast amounts of time to the                    
          operations at Sugar Tree.  First, petitioners were well aware               
          from their experience as horse owners of the requirements for               
          boarding horses before they commenced activity at Sugar Tree.               
          Second, horse-boarding, unlike other horse-related endeavors,               
          such as breeding and training, while it entails risk, to be sure,           
          is rather simple in its day-to-day execution; horses are taken              
          out to pasture (“turned out”), fed, returned to stables to rest,            
          taken out again, fed again, and retired to their stables.  There            
          is nothing in the record that suggests that petitioners were not            
          well versed and extremely competent in these practices.                     
               Finally, although we suspect that Mr. Rozzano’s testimony              
          that he spent every weekend and holiday for 10 years performing             
          upkeep at Sugar Tree may be an overstatement, we find him a                 
          credible and forthright witness overall and moreover, we believe            
          that he performed most, if not all, of the major upkeep projects            
          on Sugar Tree himself.  Therefore, we believe that the expertise            








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