Courtney C. Haun and Rebecca F. Haun - Page 17

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          the roping horse activity (viz. between $65,000 and $70,000) is             
          belied by evidence in the record showing that the most that was             
          received over the period 1991 through 1996 from the sale of a               
          roping horse was $1,000 during 1993.                                        
               On the record before us, we find that petitioners have                 
          failed to establish that they intended in good faith that any               
          expected appreciation in the value of the assets used in the                
          roping horse activity, when realized, would, together with any              
          income from that activity, exceed the expenses therefrom.                   
               We have considered and reject all of petitioners' other                
          claims and contentions with respect to the roping horse activity.           
               Based on our review of the entire record before us, we find            
          that petitioners have failed to prove that during the years at              
          issue the roping horse activity was an activity engaged in for              
          profit within the meaning of section 183.  Accordingly, we                  
          sustain respondent's determinations.                                        
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               






               7(...continued)                                                        
          roping horse activity, we would have expected Mr. Haun's                    
          recollection about the number of horses used in that activity to            
          be clear and specific.                                                      




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