Martin and Marion Abbene - Page 22

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            of his vacation time to operating Blue Ribbon.  Therefore,                                   
            despite Mr. Abbene's outside employment with Pride Chemicals, we                             
            conclude that the time and effort expended by Mr. Abbene is a                                
            factor that favors petitioners.                                                              
                  4.    Expectation That Assets Used in the Activity May                                 
                        Appreciate in Value                                                              
                  An expectation that assets used in the activity may                                    
            appreciate in value may be an indication of a profit objective.                              
            Engdahl v. Commissioner, 72 T.C. 659, 668 (1979); sec. 1.183-                                
            2(b)(4), Income Tax Regs.                                                                    
                  Respondent argues that petitioners had no expectation of                               
            asset appreciation.  Petitioners contend that they sincerely and                             
            reasonably believed that the property and the horses used in Blue                            
            Ribbon's operations would appreciate in value.                                               
                  Petitioners contend that the property had nearly doubled in                            
            value since its acquisition in 1975.  Although petitioners point                             
            to the value of the property, we do not consider it to be                                    
            relevant to the issue of Mr. Abbene's profit objective with                                  
            respect to his horse-related activities.  While the term "profit"                            
            may contemplate appreciation in the value of assets, including                               
            land, used in the activity, sec. 1.183-2(b)(4), Income Tax Regs.,                            
            the holding of land for appreciation will generally be considered                            
            a separate activity for purposes of ascertaining a profit motive                             








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