Richard H. Daley and Estate of Anne H. Daley, Deceased, Richard H. Daley, Executor - Page 13

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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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