- 33 -                                         
          section 183.21  We shall therefore treat each such activity as a            
          separate activity for those purposes.                                       
               Petitioner's Horse Activity                                            
               At all relevant times, petitioner has enjoyed equestrian               
          activities.  During the early 1970's, he owned a horse, took                
          riding lessons, and learned how to train a horse (1) to perform             
          at an unspecified level in dressage and (2) to do low-level                 
          jumps, provided that the horse had received some training in                
          jumping.  During 1988, petitioner, who did not have any formal              
          training as a horse trainer or horse breeder, acquired Moon-                
          shadow, a horse that had had some training in riding and jumping.           
          He planned to train Moonshadow in dressage, jumping, and/or                 
          cross-country riding--activities that petitioner knew would                 
          expose that (and any other) horse to a significant risk of                  
          injury.  Petitioner hoped to be able to sell Moonshadow after it            
          was trained.  However, the record does not establish that during            
          the years at issue petitioner had or attempted to acquire the               
          expertise that he needed to carry out the training that he                  
          testified he envisioned for Moonshadow (and the other horses that           
          he acquired) or that he consulted with others who had such                  
          21  Even assuming arguendo that we had found that, during 1990              
          and 1991, petitioner's horse activity and his cattle activity               
          constituted one activity for purposes of sec. 183, on the record            
          before us, we would nonetheless find that petitioner has failed             
          to establish that he was engaged in that activity during those              
          years with the requisite profit motive within the meaning of sec.           
          183.                                                                        
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