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to see how those physical problems affected the profitability of
petitioner's horse activity for any of the preceding years,
including the years at issue.
We have considered and reject all of petitioner's other
claims and contentions with respect to his horse activity.
Based on our review of the entire record before us, we find
that petitioner has failed to establish that during the years at
issue his horse activity was an activity engaged in for profit
within the meaning of section 183. Accordingly, we sustain
respondent's determinations that the deductions that petitioner
claimed for 1989, 1990, and 1991 relating to his horse activity
are limited by section 183(a) and (b).
Petitioner's Cattle Activity
During 1990, petitioner, who did not have any formal train-
ing as a cattle breeder, purchased for $3,000 a herd of cattle
consisting of a bull and four cows with calf. The cows produced
calves during 1990 or 1991 and each year thereafter. Petitioner
kept his cattle on the NLC land. During the winter months, they
consumed approximately five bales of hay that cost about $35 to
$50 a bale, and, during the remainder of the year, they consumed
the grass on the NLC land.
Petitioner kept the calves produced by his cows for six to
seven months until they weighed around 250 pounds, at which time
he sold them for approximately $250 each.
During 1991, petitioner received $1,024 from the sale of the
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