- 40 - 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 thePage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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