Paula L. Wilson - Page 3

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          filed.  Pursuant to section 7463(b), the decisions to be entered            
          are not reviewable by any other court, and this opinion shall not           
          be treated as precedent for any other case.  The issue for                  
          decision is whether petitioners are entitled to certain                     
          deductions relating to their horse-breeding activity for 2002.              
               At all relevant times, Paula Wilson and Michael Ryan                   
          (collectively, petitioners) have been law enforcement officers.             
          In 1995, petitioners established Wilson Ryan Quarter Horses, a              
          horse training and breeding operation (the activity).  Ms. Wilson           
          had significant experience in training horses (i.e., she began              
          training horses at age 9) and was responsible for the training of           
          petitioners’ horses.                                                        
               Petitioners routinely woke up before 5:00 a.m. each day to             
          clean the horse stalls and feed the horses; returned from their             
          respective law enforcement duties at 5:00 p.m.; and fed, trained,           
          and cared for the horses late into the night.  In addition,                 
          petitioners kept continuous watch over the horses during breeding           
          and foaling seasons.                                                        
               From 1995 through 2002, Ms. Wilson attended exhibitions and            
          advertised in trade magazines to promote Wilson Ryan Quarter                
          Horses.  In addition, she consulted with trainers, doctors, and             
          nutritionists to care for the horses properly.  Mr. Ryan                    

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