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activity, as well as his or her consultation with experts, may be
indicative of a profit intent. Id.
Mr. Dodge joined several horse associations, and he attended
clinics and seminars to learn how to show, train, breed, and sell
horses. Mr. Dodge also spent thousands of dollars having his
horses trained by professional trainers. Mr. Dodge did become
expert and knowledgeable about horses. His expertise, however,
focused on horse breeding and training and not the economics of
the activity. See Burger v. Commissioner, supra. The fact that
Mr. Dodge was skilled in the art of horse breeding is a factor to
be considered and does not alone show the horse activity was for
profit. Glenn v. Commissioner, T.C. Memo. 1995-399, affd.
without published opinion 103 F.3d 129 (6th Cir. 1996).
Significantly, petitioners did not seek professional or economic
advice on the economic aspects of horse breeding. The only
advice that Mr. Dodge sought prior to beginning the horse farm
was information on the deductibility of losses for tax purposes.
Mr. Dodge did not analyze or consult with others about the amount
of expenses that they were likely to incur. The failure to seek
professional advice is another factor that indicates a lack of
profit motive. Burger v. Commissioner, supra; Ballich v.
Commissioner, supra.
3. Time and Effort Spent in Conducting the Activity
We next consider the time and effort spent by petitioners in
conducting their horse-breeding activity. Sec. 1.183-2(b)(3),
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