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After concessions,1 the issues for decision are: (1)
Whether petitioner conducts her equestrian and related activities
as part of her design business; (2) whether these activities are
for profit under section 183(a);2 and (3) if the activities are
for profit, whether the expenses associated with the equestrian
activity are ordinary and necessary expenses under section
162(a). We hold that: (1) Petitioner conducts her equestrian
and related activities as part of her design business; (2)
petitioner’s design and equestrian activities are conducted for
profit; and (3) the equestrian-related expenses associated with
her activity are ordinary and necessary expenses.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Wellington, Florida, at the time of filing
the petition.
In 1998, petitioner was 46 years old and in the middle of a
bitter divorce. She had no means of supporting herself.
Petitioner held no job, had no college degree, and had not had
1Petitioner concedes that she is not entitled to claim
Schedule C, Profit or Loss From Business, expenses amounting to
$26,158 and $7,402 for her interior design activity in 1999 and
2000, respectively.
2All section references are to the Internal Revenue Code in
effect for the years at issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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