- 8 - regularly consulted with Mil Barton. Mr. Barton, with his 40 years of experience in the horse breeding and showing business, advised petitioners on how to breed a successful horse and how to make a profit in the Activity. In addition, petitioners hired veterinarians and trainers to board and care for their horses. These facts are consistent with petitioners' intention to make a profit. III. Time Devoted to the Activity The fact that a taxpayer devotes substantial personal time and effort to carrying on an activity may indicate an intention to derive a profit. Sec. 1.183-2(b)(3), Income Tax Regs. The fact that the taxpayer devotes a limited amount of time to an activity, however, does not necessarily indicate a lack of profit objective where the taxpayer employs competent and qualified persons to carry on the activity. Id. Petitioners did not personally devote a substantial amount of time to the Activity. They did, however, hire competent and qualified persons to assist them in conducting the Activity. Petitioners hired Mil Barton and Mike Van Leuven to perform the training necessary to produce a quality show horse. Mr. Barton fed and cared for Hot Twist and attended horse shows with Hot Twist when Mr. Dawson could not attend. As discussed above, Mr. Barton was competent and qualified in the horse breeding and showing business. As a result, the fact that petitioners did notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011