STRICKLAND v. COMMISSIONER

Docket No. 2241-99.

80 T.C.M. 451 (2000)

T.C. Memo. 2000-309

Roderick P. Strickland and Linda G. Strickland v. Commissioner.

United States Tax Court.

Filed September 28, 2000.


Attorney(s) appearing for the Case

F. Pen Cosby, for the petitioners. Timothy A. Lohrstorfer, for the respondent.


MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax of $13,398 for 1995 and $10,687 for 1996.

Petitioners began to breed horses in 1993 and began to board horses in 1995. The sole issue for decision is whether petitioners operated their horse breeding and boarding activity (horse activity) for profit under section 183 in 1995 and 1996. We hold that they did.

Section...

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