Michael T. Shane - Page 7

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          County and Maryland Casualty Co.  Respondent determined that                
          petitioner's horse activity did not constitute an activity                  
          engaged in for profit under section 183.  Accordingly, respondent           
          disallowed the losses claimed by petitioner.                                
                                       OPINION                                        
               We must decide whether section 183 applies to petitioner's             
          horseracing and horse-breeding activity.  Respondent maintains              
          that petitioner's lack of a profit objective precludes him from             
          deducting the expenses attributable to that activity in excess of           
          those which are allowed by section 183.  In contrast, petitioner            
          contends that he possessed the requisite profit objective during            
          the years at issue and, therefore, section 183 is inapplicable.             
          Accordingly, petitioner argues that the expenses attributable to            
          his horse activity are fully deductible under section 162.  We              
          agree with petitioner.                                                      
               Section 183 allows only specified deductions unless an                 
          activity is engaged in for profit.  Section 183(c) defines an               
          activity not engaged in for profit as any activity other than one           
          with respect to which deductions are allowable for the taxable              
          years under section 162 or under paragraphs (1) or (2) of section           
          212.  Petitioner argues that he engaged in the horse activity               
          with the requisite profit objective; respondent disagrees.                  
               An activity engaged in for profit is one in which the                  
          taxpayer has an actual and honest objective of making a profit.             
          Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without             




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