- 18 - 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-Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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