Michael T. Shane - Page 19

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          intensive horse activity, this is not sufficient to cause the               
          activity to be classified as not engaged in for profit if the               
          activity is, in fact, engaged in for profit as evidenced by other           
          factors.  Sec. 1.183-2(b)(9), Income Tax Regs.  Accordingly, we             
          find that this factor weighs in petitioner's favor.                         
               Having considered the facts and circumstances of this case,            
          we conclude that, during the years at issue, petitioner engaged             
          in his horse activity with an actual and honest objective of                
          making a profit.                                                            
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered under Rule 155.                  


























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