- 20 - Petitioners contend that Mr. Abbene possessed the requisite expertise to operate Blue Ribbon in a profitable manner, and that he regularly consulted others who had expertise in the activity. Respondent argues that Mr. Abbene lacked expertise with respect to the economics of running a profitable horse farm, and that petitioners failed to present any evidence that Mr. Abbene consulted outside experts in an effort to improve Blue Ribbon's profitability. We agree with respondent. Mr. Abbene, a longstanding member of several horseman's associations, has owned horses for most of his adult life. We do not doubt his expertise and knowledge about horses. Mr. Abbene's expertise, however, did not focus on the economic aspects of the activities in which Blue Ribbon engaged. Petitioners made no showing that Mr. Abbene undertook a study of the accepted business and economic practices with respect to the activities of his horse farm or that he consulted with outside experts concerning the profitability of Blue Ribbon. Petitioners failed to show that Mr. Abbene sought or acquired the expertise that would enable him to turn his horse farm into a profitable business. See Golanty v. Commissioner, supra at 432. The failure to seek professional advice is another factor that indicates a lack of profit motive. Id.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011