- 14 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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