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breeding and training business indicates a lack of profit
objective. We conclude, however, that this factor is outweighed
by the other factors considered above.
Having considered the factors listed in section 1.183-2(b),
Income Tax Regs., all contentions presented by the parties, and
the facts and circumstances of this case, we hold that
petitioners actually and honestly intended to make a profit in
the Activity. Consequently, section 183 does not limit the
deductions claimed by petitioners with respect to the Activity.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011