Kenneth E. Perry and Mary A. Hofer - Page 25

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             years in issue.  Thus, appreciation in the value of the                  
             land used in the activity helps to explain petitioners'                  
             willingness to continue their horse breeding and boarding                
             operation despite the operating losses sustained during the              
             years in issue.  Cf. Allen v. Commissioner, 72 T.C. at 36.               
             This is strong evidence that petitioners conducted that                  
             activity with an honest and actual objective of making a                 
             profit.  See, e.g., id.; Fields v. Commissioner, T.C. Memo.              
             1981-550; Sanderson v. Commissioner, T.C. Memo. 1964-284.                

                  5.  Success in Similar or Dissimilar Activities                     
                  Petitioners both testified that they had been                       
             involved in purchasing, breeding, training, and selling                  
             horses in the past.  While there is no evidence in the                   
             record to substantiate their success in these activities,                
             we find their testimony to be credible.  There is no                     
             evidence that Mr. Perry or Ms. Hofer was successful in                   
             any dissimilar investment or business activities.                        

                  6.  History of Income or Losses                                     
                  Petitioners reported a net loss from their horse                    
             activity during each of the years in issue.  We also note                
             that petitioners suffered 2 years of extreme drought,                    
             during which they were unable to produce their own feed,                 
             the market price of feed increased, and the market for                   
             horses decreased.  Cf. Fields v. Commissioner, supra.  We                




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