Martin and Marion Abbene - Page 20

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                  Petitioners contend that Mr. Abbene possessed the requisite                            
            expertise to operate Blue Ribbon in a profitable manner, and that                            
            he regularly consulted others who had expertise in the activity.                             
            Respondent argues that Mr. Abbene lacked expertise with respect                              
            to the economics of running a profitable horse farm, and that                                
            petitioners failed to present any evidence that Mr. Abbene                                   
            consulted outside experts in an effort to improve Blue Ribbon's                              
            profitability.                                                                               
                  We agree with respondent.  Mr. Abbene, a longstanding member                           
            of several horseman's associations, has owned horses for most of                             
            his adult life.  We do not doubt his expertise and knowledge                                 
            about horses.  Mr. Abbene's expertise, however, did not focus on                             
            the economic aspects of the activities in which Blue Ribbon                                  
            engaged.  Petitioners made no showing that Mr. Abbene undertook a                            
            study of the accepted business and economic practices with                                   
            respect to the activities of his horse farm or that he consulted                             
            with outside experts concerning the profitability of Blue Ribbon.                            
            Petitioners failed to show that Mr. Abbene sought or acquired the                            
            expertise that would enable him to turn his horse farm into a                                
            profitable business.  See Golanty v. Commissioner, supra at 432.                             
            The failure to seek professional advice is another factor that                               
            indicates a lack of profit motive.  Id.                                                      








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