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no substantial personal or recreational elements associated with
such activity. Sec. 1.183-2(b)(3), Income Tax Regs. Petitioner
maintains that he spent 10 to 12 hours each week engaged in his
horse activity. Yet he failed to produce credible evidence
explaining the type of work he performed. The available evidence
indicates that petitioner spent much of his time riding his
horses. Petitioner contends, however, that such riding was not
recreational. Instead, petitioner maintains that his riding
served several business purposes, including exercising and
training. Petitioner also maintains that the reason he rode his
horses during competitive events was to develop a better
appreciation for his business and illustrate to perspective
purchasers that his horses were suitable for novice riders.
The record does not support petitioner's arguments.
Essentially, by relying on Costello to maintain and train his
horses, petitioner avoided the rigors of his horse activity and
indulged himself with its pleasantries. Petitioner's testimony
otherwise is simply not credible, and we are reluctant to accept
Costello's testimony as corroboration in light of his business
relationship with petitioner. We conclude that petitioner's
horse activity contained substantial elements of a recreational
and personal nature. Accordingly, we find that this factor
favors respondent.
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