- 15 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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