- 12 - competition winnings and gain from the sale of one of her horses from her Schedule C to “other income”. Further, the notice disallowed all of petitioner’s Schedule C horse-related expenses, explaining: It has been determined that the amounts claimed as Schedule C horse racing expenses for the tax years ending 12/31/99, 12/31/2000 and 12/31/2001 are not allowable as such since said activity is deemed to be an activity not engaged into for profit. It has further been determined that said expenses are allowable as Schedule A expenses subject to the applicable Adjusted Gross Income limitations. Accordingly, your taxable income is increased by the disallowed expenses adjustment amounts. The notice also disallowed some of the expenses associated with petitioner's horse barn/interior design activity, explaining: It has been determined that adjustments are warranted to correct your claimed Schedule C expenses from your Interior Decorating Activity for the tax years ending 12/31/1999 and 12/31/2000. The adjustments are a result of a disallowance of expenses. The expenses have been disallowed because you have not established that these amounts were incurred, or, if incurred, paid by you during the taxable year for ordinary and necessary business purposes, or that these expenses were deductible under the provisions of the Internal Revenue Code. Accordingly, your taxable income is increased by the adjustment amounts. Petitioner timely filed her petition with this Court. In her petition, petitioner assigned error to respondent’s segregation of the equestrian and interior design activities andPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 NextLast modified: November 10, 2007