- 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.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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