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Tax Regs., and take all facts and circumstances into
account. See Hoyle v. Commissioner, supra.
We find petitioners' characterization of their horse
breeding and boarding, and holding of the land as a single
activity to be fully supported by the facts of this case.
See generally Keanini v. Commissioner, supra at 46.
Petitioners purchased the subject land in Union County,
Ohio, for the purpose of breeding and boarding horses
thereon. They considered the cost of the land as part of
the cost of the horse breeding and boarding undertakings.
Petitioners constructed horse barns on the land, and
converted the use of the land to pasture, alfalfa, and hay
fields for the purpose of grazing and feeding their horses.
Thus, a close organizational and economic relationship
exists between the breeding and boarding operation and the
holding of the land for appreciation in value. Cf. id.;
sec. 1.183-1(d)(1), Income Tax Regs.
Factors Relating to the Horse Breeding and Boarding
Activity
Section 1.183-2(b), Income Tax Regs., lists the
following factors relevant to determining whether an
activity is engaged in for profit: (1) The manner in
which the taxpayer carries on the activity; (2) the
expertise of the taxpayer or his advisors; (3) the time
and effort expended by the taxpayer in carrying on the
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