Donald Keith Morley and Rebecca B. Morley - Page 11

                                       - 11 -                                         

          Income Tax Regs.; cf. Dunn v. Commissioner, 70 T.C. 715, 720                
          (1978), affd. 615 F.2d 578 (2d Cir. 1980).                                  
               Petitioners contend that the losses from the horse-breeding            
          activity are properly deductible because the activity was profit            
          motivated.  Conversely, respondent asserts that the activity was            
          not engaged in for profit.  We find that Mr. Morley engaged in              
          the horse-breeding activity with the primary purpose and dominant           
          hope and intent of realizing a profit.                                      
               A.   Manner in Which the Activity is Conducted                         
               Relevant factors in determining profit motive include                  
          whether the taxpayer:  Maintained complete and accurate books and           
          records, conducted the activity in a manner substantially similar           
          to other comparable businesses which are profitable, and                    
          attempted changes in order to improve profitability.  Sec. 1.183-           
          2(b)(1), Income Tax Regs.                                                   
               Respondent argues that Mr. Morley failed to operate his                
          horse-breeding activity in a businesslike manner.  Mr. Morley               
          kept extensive records.  In managing the farm, Mr. Morley used              
          business documents.  His books and records for the farm included            
          teasing and breeding records on his horses, self-generated                  
          pedigrees for each of his horses, and veterinarian and other                
          types of health records on his horses.  He insured the horses               
          that he purchased under contract.                                           
               Respondent also points to the fact that Mr. Morley did not             
          create or follow a written business plan, and did not prepare any           



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