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them to continue to operate Blue Ribbon notwithstanding its heavy
losses and to seek to have the Government subsidize a portion of
its costs. See, e.g., Gircsis v. Commissioner, T.C. Memo. 1992-
244; Purdey v. Commissioner, T.C. Memo. 1989-657, affd. without
published opinion 922 F.2d 833 (3d Cir. 1990).
9. Elements of Personal Pleasure or Recreation
The presence of personal motives in the carrying on of an
activity may indicate that the activity is not engaged in for
profit, especially where there are recreational or personal
elements involved. Sec. 1.183-2(b)(9), Income Tax Regs.
Petitioners concede that Mr. Abbene derived pleasure from
his horse-related activities but argue that his love of horses
does not indicate a lack of profit motive. To the contrary,
petitioners contend that Mr. Abbene’s prior investment of time,
love, and money formed a natural basis from which to enter into a
business.
To be sure, enjoyment of one's work is not inconsistent with
a profit motive. See Jackson v. Commissioner, 59 T.C. 312, 317
(1972). On the record before us, however, we are not convinced
that either Blue Ribbon or Mr. Abbene engaged in the horse-
related activities with an actual and honest profit objective.
Accordingly, Blue Ribbon is not entitled to take deductions for
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