Renee Harding

Tax Case Exercise

In January $2022,$ Renee Harding and her husband were divorced after $20$ years of marriage. She received a substantial property settlement that included the house and an adjoining office set on five acres of land. Two$-$thirds of the office and the land were used by Renee$$s daughter for horse stables and a riding arena.

Her annual alimony allowance allows Renee to live a comfortable life without working. Renee had never worked outside of the house, spending her time instead taking classes, traveling and playing tennis. In $2007,$ Renee earned a bachelors degree in art from a nearby state university.

For several years, Renee owned two purebred terriers as pets, and she developed an interest in raising, breeding, and showing them for profit. To keep herself busy after the divorce, Renee decided to purchase five terriers to start breeding in February $2022.$

Renee had part of the office converted into a ten$-$pen kennel. She purchased an advertisement in Dog World for her services as a breeder, and signed onto the breeding network. In the summer of $2022,$ Renee attended several dog shows across the country, and spent a lot of time with friends because the shows sponsored many social activities.

Renee maintained detailed records for each terrier purchased, with space for all the stud fees, receipts from the sale of puppies, and the cost of caring for the dog. The closest veterinarian was twenty minutes away. In December $2022,$ Renee sold one puppy from her first litter of five. The net loss from the operation in $2022$ was $$25,406.$

Required:

Find two court cases that would support Renee treating her loss from dog breeding activities as a business loss. Explain why these authorities are appropriate to use in Renee$$s situation $($i$.$e$.,$ explain why these are a $$good fit$$ for Renee$).$

Find one court case with similar facts that did not support treatment of the loss as a business loss and distinguish it from Renee$$s situation.