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Petitioner asserts that she is a lifelong experienced
businesswoman who before starting the horse activity read books,
viewed videos, and consulted with experts consisting of her
sister, her (petitioner’s) daughter, a professional horse
trainer, and an individual who bred and judged horses in Europe.
Petitioner also asserts that she joined relevant trade
associations in 1985 and that she was knowledgeable of some
veterinarian services and the training and showing of horses.
Petitioner concludes that this factor weighs in her favor. We
disagree.
The mere fact that petitioner may have aspired to breed
horses does not necessarily mean that she entered into the horse
activity with the requisite profit objective. The credible
evidence in the record does not establish that petitioner read or
viewed the referenced materials or consulted with her so-called
experts before entering into the horse activity in 1988. While
petitioner testified generally that she did, she discredited that
testimony by also testifying that these happenings were not until
3 years after she bought her first horse. She also did not
specify or otherwise elaborate on the referenced books or videos,
other than to say that they were breeding and training books and
veterinarian manuals, or the advice that she purportedly received
from the trainer, the breeder/judge, or her sister and daughter;
e.g., was it general advice regarding showing and promoting
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