Rhett Rance Smith and Alice Avila Smith, et al. - Page 22




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          world.  Zane has not won more than nominal amounts showing dogs,            
          and he did not earn any income from judging during the years at             
          issue.                                                                      
               Zane did not have a written business plan for his dog                  
          breeding activity.  He did not keep a separate checking account             
          for his dog breeding activity.  When he wrote a check, he noted             
          the purpose of the expense.  At the end of the year, Zane                   
          summarized the expenses for his C.P.A. for purposes of preparing            
          his returns.  Zane spent approximately 10 to 20 hours each week             
          on the dog breeding activity and was showing one or two dogs                
          regularly and three or four dogs less often.                                
               Zane had two Staffordshire Bull Terriers living with him in            
          New York from 1996 through 2003, and his other dogs lived with              
          professional handlers.  In addition, Zane coowned some dogs that            
          lived with his coowners.  Zane had no income from the dog                   
          breeding activity in any of the years 1996, 1997, 1998, 1999, and           
          2000. Zane’s 1997 Schedule C, Profit or Loss From Business,                 
          reflected no income and $52,683 in expenses.  Zane’s Schedules F            
          attached to his other returns were entitled “Cattle Crops–-Dog              
          Breeding” and for 2004 included the term “Organic Dairy Milk”.              
          Some of them reflected income, but the source was not specified.            
               The following table shows the losses Zane claimed for the              
          dog breeding activity for the years 1997 through 2004:                      








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