Tracey L. Topping - Page 12




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          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 and            










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