- 31 - 9. Elements of Personal Pleasure Petitioners did not conduct their horse and rodeo activity for their personal pleasure. Mr. Brockenbrough wanted to live on a farm after he retired from Delta, but this fact does not show that petitioners lacked a profit objective. This factor favors petitioners. 10. Respondent's Other Contention Respondent contends that Mr. Brockenbrough's letter to the Meriwether Cattlemen's Association dated February 23, 1992, in which he said that he hoped that he would "at least break even for once" shows that petitioners did not have a profit motive. We disagree. We believe respondent is misconstruing Mr. Brockenbrough's statement in that letter, and that the letter shows that petitioners wanted to make money. 11. Conclusion Petitioners conducted their horse and rodeo activity in a businesslike manner, consulted experts, kept adequate records, developed expertise in the business, did not own the horses for personal pleasure, and adjusted their plan in their attempt to make a profit. Mr. Brockenbrough spent many hours performing physical labor and menial chores. Petitioners abandoned their horse and rodeo activity because of the death of some of their horses, difficulties with Bumgarner, and other causes beyondPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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