- 2 - 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. Background 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. RyanPage: Previous 1 2 3 4 5 6 7 8 NextLast modified: November 10, 2007