- 42 - hypothetically that "you can buy a horse for $10,000 * * * start breeding it, selling its babies for an equal amount and after you sold the first one you could recapture your loss for the initial investment." This statement, taken on its face, seems to support petitioner's assertion that he expected his stallion to appreciate in value because it could be used for breeding purposes. Petitioner, however, never owned a stallion that could potentially appreciate. In fact, according to a veterinarian's soundness examination given to the animal prior to petitioner's purchase, it was determined that the horse was not actually a stallion as petitioner asserts, but rather a gelding. Petitioner also testified that he could generate capital gain from the sale of his horses, since they would appreciate from being displayed at horse shows. However, petitioners had no income from either selling or breeding horses. Accordingly, we find that petitioners' horses could not be expected to significantly appreciate in value. E. Taxpayer's Success in Other Activities We have recognized that a taxpayer's success in other business activities may indicate a profit motive, despite a currently unprofitable activity. Hoyle v. Commissioner, T.C. Memo. 1994-592; sec. 1.183-2(b)(5), Income Tax Regs. During the years in issue, petitioner, a retired police officer, is also reporting substantial losses on his Schedules C from another business activity known as TSI. The losses from that activityPage: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
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