Craig v. Comr., T.C. Sum. Op. 2013-58

(petitioner worked 25-40 hours weekly as real estate agent and an additional 25-30 hours weekly in horse activity and worked part-time preparing tax returns; petitioner sustained losses in horse activity and claimed associated deductions; IRS denied deductions; while IRS didn't question hours petitioner spent in horse activity, IRS determined that petitioner lacked profit intent; petitioner prepared business plan for horse activity after IRS audit began and petitioner had only accomplished one of 10 items on business plan; no separate bank account maintained for horse activity, but expenses run through petitioner's personal account; gross receipts from activity only reported in one of seven years; court sustained IRS position and imposed 20 percent accuracy-related penalty).