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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 beyond
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