- 22 - We disagree with respondent. Petitioners herein lost the two substantive tax issues in this case largely because of objective factors not in their favor and because of their burden of proof on those issues. Petitioners, however, did impress us with their general testimony and credibility. We note the many cases in which a profit objective has been found to be present in connection with horse breeding and horse racing activities in the face of substantial losses over a number of years. See e.g., Engdahl v. Commissioner, 72 T.C. 659 (1979); Holbrook v. Commissioner, T.C. Memo. 1993-383; Scheidt v. Commissioner, T.C. Memo. 1992-9; Stephens v. Commissioner, T.C. Memo. 1990-376. We also believe it appropriate and necessary in this case, particularly in considering additions to tax in the context of an issue arising under section 183, to take into account, as explained previously herein, the fact that the case law and regulatory authority under section 183 establish very clearly that a taxpayer's professed profit objective in engaging in an activity need not be "reasonable". We conclude, under the facts of this case, that petitioners filed valid extension applications for their 1988 Federal income tax returns and on August 15, 1989, timely filed their 1988 Federal income tax returns. We also conclude that petitioners were not negligent in filing their 1988 Federal income tax returns, and that petitioners had substantial authority for thePage: 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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