- 27 - operation of their horse activity and from the appreciation in the value of the horses once it was realized. Petitioners had a world champion Arabian, Bella Joya, which earned them a substantial amount of money. Petitioners bred Bella Joya to Wiking, another champion horse, to produce a foal that they could race. The foal, however, had to be put to sleep. Bella Joya has produced another foal, which petitioners intend to race. Additionally, petitioners' horses were appraised in 1995 at a value of between $96,000 and $106,000. During the years in issue, however, petitioners were hampered by their bankruptcy payments and by Mrs. Phillips' numerous medical problems. Once they are no longer hindered by such considerations, petitioners will be able to invest more time and money on their horse activity. Accordingly, based on the record, we conclude that petitioners intended that an overall profit would result from the operation of their horse activity and from the appreciation in the value of the horses once it was realized. Section 1.183-2(b)(6), Income Tax Regs., provides that "A series of losses during the initial or start-up stage of an activity may not necessarily be an indication that the activity is not engaged in for profit." The regulations continue:Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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