- 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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