Michael J. Rozzano, Jr., and Rose Marie Rozzano - Page 20




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               Moreover, we note that the variable costs of petitioners’              
          horse-boarding activities, including fees, veterinarian care,               
          etc., exceeded the gross income produced by the activities, with            
          the result that the horse-boarding activities do not meet the               
          test imposed under the regulation pertaining whether such                   
          activities will be integrated.  See sec. 1.183-1(d)(1), Income              
          Tax Regs.   Accordingly, we believe, in this case, that their               
          holding the property for appreciation and horse-boarding are                
          separate activities.  See sec. 1.183-2(b)(4), Income Tax Regs.;             
          Engdahl v. Commissioner, 72 T.C. 659 (1979);  Allen v.                      
          Commissioner, 72 T.C. 28 (1979).   Irrespective of this                     
          conclusion, however, we do not believe that petitioners’                    
          inability to argue the appreciation of their land is ultimately             
          determinate on the issue of whether the horse-boarding activity             
          was engaged in for profit.                                                  
          Financial Status of the Taxpayers                                           
               The fact that petitioners have substantial income from                 
          sources other than the activity at issue may indicate that the              
          activity was not engaged in for profit.  Cf. Engdahl v.                     
          Commissioner, 659, 670.  Respondent argues that Mr. Rozzano’s               
          income from his job in executive management was sufficient to               
          absorb the expenses in operating Sugar Tree, indicating that it             
          was not operated for profit.  We disagree.  As previously stated,           
          these out-of-pocket expenditures were 34 percent and 46 percent             







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