Donald Keith Morley and Rebecca B. Morley - Page 13

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          provided notices and narratives about every horse to potential              
          purchasers.  Based on the facts of this case, we find that Mr.              
          Morley carried on the horse-breeding activity in a businesslike             
          manner, and this indicates a profit motive.                                 
               B.   Expertise of Mr. Morley and His Advisers                          
               A taxpayer's expertise, research, and study of an activity,            
          as well as his consultation with experts, may be indicative of a            
          profit motive.  Sec. 1.183-2(b)(2), Income Tax Regs.  Respondent            
          argues that the type and quality of advice sought by Mr. Morley             
          was not indicative of an intent to engage in an activity for                
          profit.                                                                     
               Prior to 1985, Mr. Morley had no knowledge about breeding              
          Arabian horses.  Initially, he discussed the Arabian horse-                 
          breeding business with Mr. Horton.  Mr. Horton had been in the              
          horse-breeding business for many years and the community regarded           
          him as having a quality reputation for his knowledge of the                 
          business operations and the area horse market.  Mr. Horton                  
          provided projections to Mr. Morley of the potential profit from             
          the horse-breeding activity.  Additionally, Mr. Horton assisted             
          Mr. Morley's entry into Arabian horse breeding.                             
               Mr. Morley also consulted with other horse breeders and read           
          journal articles for information about horse breeding.  He                  


               8(...continued)                                                        
          country to mean that people located in this part of the country             
          are devoted fans of the University of Tennessee.                            



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