Martin and Marion Abbene - Page 25

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            successfully produced one foal, albeit one of limited value,                                 
            petitioners concede that Mr. Abbene made no further attempt to                               
            breed Spectacular Rhythm.  Petitioners assert that Mr. Abbene                                
            encountered difficulties breeding Nakita.  Yet, aside from a                                 
            vague reference to fertility problems, the record is devoid of                               
            any evidence regarding any specific attempts to breed Nakita                                 
            during the years in issue.  We conclude that there is no evidence                            
            in the record that justifies Mr. Abbene's claimed expectation of                             
            appreciation in the value of the horses used in Blue Ribbon's                                
            operations.                                                                                  
                  Moreover, it is necessary that the taxpayer's objective be                             
            to realize a profit on the entire operation.  Bessenyey v.                                   
            Commissioner, 45 T.C. 261, 274 (1965), affd. 379 F.2d 252 (2d                                
            Cir. 1967).  This would require future net earnings and                                      
            appreciation sufficient to recoup the losses which the taxpayer                              
            sustained in prior years.  Id.  Petitioners, however, failed to                              
            produce any credible evidence that Blue Ribbon had any realistic                             
            chance of recovering the excessive losses incurred since its                                 
            incorporation.  In fact, petitioners conceded that they do not                               
            know when or whether Blue Ribbon will ever become profitable.                                
            Accordingly, we conclude that the expectation of asset                                       
            appreciation is a factor that weighs against petitioners.                                    








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