Tracey L. Topping - Page 11




                                       - 11 -                                         
                                   Net Loss of         Net Income of                  
               Tax Year            Horse Activity      Topping White                  
               1998                $47,123             $200,908                       
               1999                80,735              157,239                        
               2000           206,080                  499,908                        
               2001                275,169             322,459                        
          On a consolidated basis, however, petitioner’s overall business             
          enjoyed a net profit 6 of the first 7 years of the business:                
               Year      Gross Income     Cash Expenses     Net Income                
               1998      $253,965       $100,180            $153,785                  
               19991     276,453        199,949             76,504                    
               20001     707,521        413,693             293,828                   
               20011     542,183        494,893             47,290                    
               2002      523,038        485,279             37,759                    
               2003      841,564        495,422             346,142                   
               2004      498,826        506,887             (8,061)                   
                    1  Years at issue.                                                
               Petitioner is a beneficiary of the Daniel Topping Trust (the           
          trust) from which she received taxable income from 1998 through             
          2004.  For the years in question, that income consisted of                  
          $14,060 for 1999, $12,053 for 2000, and $11,882 for 2001.  For              
          all of the other years, the amount received from the trust was              
          under $20,000.                                                              
               On August 26, 2004, respondent mailed to petitioner a notice           
          of deficiency asserting deficiencies for the taxable years 1999,            
          2000, and 2001.  The notice contained no determination regarding            
          the relationship between the horse circuit and the horse                    
          barn/interior design activities.  The first two adjustments                 
          shifted the gross income which petitioner reported from her horse           







Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next 

Last modified: November 10, 2007