Courtney C. Haun and Rebecca F. Haun - Page 16

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          instant record, we are not satisfied that petitioners paid                  
          $60,000 to acquire that property.  Nor are we persuaded by Mr.              
          Haun's uncorroborated testimony that the fair market value of the           
          Haughton property at the time of the trial in this case was                 
          approximately $150,000.6                                                    
               With respect to the horses, equipment, saddles, pipe, and              
          tack used in the roping horse activity, at trial Mr Haun esti-              
          mated that those assets could be sold for an aggregate maximum              
          amount of approximately $104,000.  We are not persuaded by Mr.              
          Haun's uncorroborated testimony that, as of the date of the trial           
          in this case, such an amount could have been received upon the              
          sale of those assets.  Indeed, Mr. Haun's testimony about the               
          aggregate amount that he believed could have been received as of            
          that date from the sale of the five or six7 roping horses used in           

               6  Furthermore, we are not satisfied on the instant record             
          that the roping horse activity and the holding of the Haughton              
          property are to be considered one activity for purposes of sec.             
          183.  The deductions attributable to the roping horse activity              
          over the period 1991 through 1996 that are not directly                     
          attributable to the holding of the Haughton property far exceeded           
          the income (only $2,501) over that period that was derived from             
          that activity.  See sec. 1.183-1(d)(1), Income Tax Regs.  In                
          addition, it is significant that on Jan. 1, 1995, petitioners               
          transferred all the interests that they had in the roping horse             
          activity to their wholly owned corporation Rafter H in exchange             
          for additional voting common stock in that corporation.  However,           
          they did not transfer to that corporation at that time (or any              
          other time) any of their interests in the Haughton property.                
               7  Mr. Haun's testimony about the number of horses used in             
          the roping horse activity during 1992, 1993, and 1994 and as of             
          the trial herein was vague and/or contradictory.  If petitioners            
          had an actual and honest objective of making a profit from the              
                                                             (continued...)           




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