Rodney W. Taras and Linda K. Taras - Page 17

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          at a full-time job requiring 40 hours per week at Bethlehem,                
          while claiming that she contributed 30 hours per week year after            
          year in petitioners' horse activity.                                        

          Expectation That Assets May Appreciate                                      

               The appreciation of assets, including land used in the                 
          activity, is to be considered in determining whether a taxpayer             
          intended to derive a profit from his activity.  Sec. 1.183-                 
          2(b)(4), Income Tax Regs.  An expectation that assets used in the           
          activity may appreciate may be an indication of profit objective.           
          Engdahl v. Commissioner, 72 T.C. 659, 669 (1979).                           
               Petitioners resided on a 1-acre parcel of land during the              
          years in issue.  Petitioners maintained their horses on a                   
          separate but adjacent 2-acre parcel of land, which was owned by             
          Mr. Taras' parents.  Because petitioners do not own the land upon           
          which they kept their horses during the years at issue, we do not           
          consider the land an asset that may be used in determining                  
          whether petitioners had a profit objective.                                 
               Petitioners’ horses were the only assets used in the                   
          activity that might have appreciated.  Petitioners argue that the           
          quality of their horses improved over time and that on the basis            
          of this improvement, petitioners expected to recoup their prior             
          losses.  Mr. Taras testified that each of three horses bred from            
          the stallion Norquestor and owned by petitioners has a value of             






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