- 38 -
respect to petitioner's testimony, although, as the owner of the
horses, he was qualified to testify as to their value, we are not
required to, and we do not, accept his self-serving testimony on
that point. See Harmon v. Commissioner, 13 T.C. 373, 383 (1949).
With respect to Ms. Lyman's testimony about the value of peti-
tioner's horses, Ms. Lyman was not qualified as an expert witness
in this case and thus was not qualified to opine on the value of
petitioner's horses.
Even assuming arguendo that petitioner did, in fact, expect
the horses that he acquired to appreciate in value, he failed to
establish that he intended in good faith that any expected
appreciation in the value of those horses when realized, would
together with any other income from his horse activity, exceed
the expenses from that activity.
Petitioner further claims that the losses that he sustained
during the years 1988 through 1994 are attributable to Moon-
shadow's becoming lame during 1990 and Lily's sustaining injuries
and Zack's developing a foot disease around 1995. Losses sus-
tained because of unforeseen or fortuitous circumstances beyond
the control of the taxpayer are generally not to be considered as
29(...continued)
value of about $15,000 to $20,000 in the spring of 1996 and about
$25,000 in 1997. Petitioner disagreed with Ms. Lyman's testimony
about the value of Bunny in 1997 when he testified that, as of
the time of the trial, he expected Bunny to have a value of
between $30,000 and $50,000 in 1997. Petitioner also testified
that, as of the trial, Zack, a young horse with minimal training,
had a value of between $8,500 and $10,000.
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