James C. and Vivian C. Dodge - Page 14

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          Income Tax Regs.  The fact that the taxpayer devotes much of his            
          personal time and effort to carrying on an activity, particularly           
          if the activity does not have substantial personal or                       
          recreational aspects, may indicate an intention to derive a                 
          profit.  Id.                                                                
               Mrs. Dodge testified regarding the typical amount of work              
          performed by petitioners and their daughter in caring for the               
          horses.  The record indicates that Mr. Dodge spent approximately            
          15 hours per week, and Mrs. Dodge spent approximately 20 hours              
          per week working on the horse farm.  Accordingly, petitioners               
          spent significant amounts of time and effort carrying on the                
          horse-breeding activity.  However, Mr. Dodge and Andrea Dodge,              
          who are skilled riders, also derived substantial recreational               
          benefit from the time they spent with their horses; therefore,              
          this factor is generally neutralized.                                       
               4.  Expectation That the Assets Will Appreciate in Value               
               Another factor is the taxpayers' expectation that the assets           
          used in their breeding activity would increase in value.  Sec.              
          1.183-2(b)(4), Income Tax Regs.  Canadian Fury was the reserve              
          national champion in 1984.  The value of Canadian Fury and the              
          value of the three foals that she subsequently produced increased           
          as a result of this.  In addition, the value of the farm and land           
          increased from $72,500 in 1983 to $121,000 in 1992.  Petitioners            
          maintained the belief that the farm would eventually become                 
          profitable due to appreciation in the value of the land and                 



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