Tracey L. Topping - Page 2




                                        - 2 -                                         
               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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