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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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