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one activity). It is also similar to cases where we held that
horse breeding and other undertakings involving horses were one
activity. E.g., Scheidt v. Commissioner, supra (horse farm and
stallion syndication); Mary v. Commissioner, T.C. Memo. 1989-118
(horse farm and horse racing); Yancy v. Commissioner, T.C. Memo.
1984-431 (same). We conclude that petitioners operated their
horse and rodeo undertakings as one activity under section 183.
C. Whether Petitioners Operated Their Horse and Rodeo Activity
for Profit
We next decide whether petitioners operated their horse and
rodeo activity for profit. We apply the factors described above
at paragraph II-A.
1. Manner in Which the Activity Is Conducted
Petitioners conducted their horse and rodeo activity in a
businesslike manner. They hired professional rodeo companies and
a professional trainer. They advertised their business in trade
journals and in the local media. Cashion credibly testified that
petitioners established a solid operation by breeding good
working quarter horses.
Maintenance of complete and accurate records may indicate
that a taxpayer has a profit objective. Elliott v. Commissioner,
90 T.C. 960, 971-972 (1988), affd. without published opinion 899
F.2d 18 (9th Cir. 1990); sec. 1.183-2(b), Income Tax Regs.
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