Michael T. Shane - Page 18

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          sec. 1.183-2(b)(8), Income Tax Regs.  Petitioner is by no means a           
          wealthy individual.  In 1990, petitioner earned roughly $35,000             
          from his full-time job as a computer programmer.  Petitioner also           
          earned approximately $7,000 in 1990 from a part-time job.                   
          Petitioner's income in 1991 differed only slightly from that of             
          1990, as petitioner earned roughly $37,000 from his full-time job           
          and approximately $1,000 from his part-time job.  Further, the              
          record is devoid of evidence suggesting other sources of wealth             
          enjoyed by petitioner.  Given his income, we think it unlikely              
          that petitioner would embark on a hobby costing thousands of                
          dollars and entailing much personal labor without a profit                  
          objective.  See Engdahl v. Commissioner, supra at 670.                      
               Finally, the absence of personal pleasure or recreation                
          relating to the activity indicates the presence of a profit                 
          objective.  Schlafer v. Commissioner, T.C. Memo. 1990-66; sec.              
          1.183-2(b)(9), Income Tax Regs.  There is no question that                  
          petitioner enjoyed working with his horses; however, he equally             
          enjoyed working as a computer programmer.  It is human nature to            
          undertake those activities which we enjoy and to avoid those                
          activities which we find less appealing.  It cannot be said that            
          petitioner had any more or less enjoyment from his horse activity           
          than that which customarily should be expected from an                      
          entrepreneurial undertaking.  Petitioner did not ride his horses,           
          nor did he permit others, except qualified jockeys, to ride them.           
          Even though petitioner derived personal pleasure from his labor-            




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