Joseph E. Machado - Page 15

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          spent substantial time participating in their horse breeding and            
          horse racing activities.  Petitioners argue, therefore, that they           
          engaged in their horse breeding and horse racing activities for             
          profit.                                                                     
               Respondent argues, among other things, that petitioners did            
          not operate their horse breeding and horse racing activities in a           
          businesslike manner, that petitioners were not experts in the               
          breeding and racing of horses, and that losses incurred by                  
          petitioners in 1988 with respect to both activities were not                
          incurred in an activity engaged in by petitioners for profit.               
               We agree with respondent.  Petitioners advertised their                
          horses for sale in only 2 of the 10 years during which they                 
          engaged in their horse breeding and horse racing activities.  The           
          fact that petitioners hired trainers, purchased horses, and read            
          periodicals and manuals is equally consistent with engaging in an           
          activity as a hobby and is insufficient in this case to establish           
          a good faith profit objective.  Rule 142; Golanty v.                        
          Commissioner, supra at 430; Tripi v. Commissioner, T.C. Memo.               
          1983-483.  Petitioners did not operate their horse breeding and             
          horse racing activities in a businesslike manner.  Sec. 1.183-              
          2(b)(1), Income Tax Regs.                                                   
               Petitioners devoted a minimal amount of time to their horse            
          breeding and horse racing activities.  Sec. 1.183-2(b)(3), Income           
          Tax Regs.                                                                   






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