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personal pleasure from the Activity. Mr. Dawson admitted that he
occasionally rode the horses at his home to keep them warmed up.
As a result, respondent contends that petitioners derived
personal pleasure from the Activity. This contention, however,
is not supported by the record.
Mr. Dawson testified that neither he nor his family ever
rode the horses for pleasure, and Mr. Barton confirmed that he
was not aware of any member of Mr. Dawson's family riding the
horses for pleasure. Further, even if Mr. Dawson did derive some
satisfaction from the Activity, that is not determinative of the
issue in this case. A taxpayer can enjoy his work and still be
engaged in it for profit. See Jackson v. Commissioner, 59 T.C.
312, 317 (1972) (stating that "a business will not be turned into
a hobby merely because the owner finds it pleasurable; suffering
has never been made a prerequisite to deductibility"); Hart v.
Commissioner, T.C. Memo. 1995-55 (same). The requirement is that
a profit objective be the "basic and dominant" objective.
Independent Elec. Supply, Inc. v. Commissioner, 781 F.2d at 726.
We conclude that it was.
IX. Past Successes in Activity
The taxpayer's past success in similar or dissimilar
activities can be indicative of a profit objective. Sec.
1.183-2(b)(5), Income Tax Regs. Respondent contends that the
fact that petitioners have never conducted a successful horse
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