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including attending roping horse shows, races, and competitions.
Sometime during 1991, petitioners started the roping horse
activity on the Haughton property, which reduced somewhat Mr.
Haun's participation in those recreational activities. However,
petitioners have failed to establish that during the years at
issue (or at any other time) they projected the future income,
expenses, or profits that they expected to be generated by the
roping horse activity. Although during the years at issue
petitioners apparently retained adequate records relating to the
expenses that they incurred in the roping horse activity so as to
enable them and respondent to stipulate to the amount of loss for
each such year to which they would be entitled in the event that
the Court were to find that they engaged in that activity with an
objective of making a profit within the meaning of section 183,3
they have not established that they had a business plan for
generating a profit from the roping horse activity.
Prior to the years at issue, Mr. Haun consulted a lawyer who
advised him to incorporate the roping horse activity, which
petitioners did prior to 1993. Mr. Haun also consulted a certi-
fied public accountant, who prepared petitioners' 1991 return,
and two professional horse trainers who discussed with Mr. Haun
the demand for and the difficulty of finding good horses, the
prices at which certain horses were bought and sold, certain team
3 See supra note 2.
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