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Significantly, petitioner did not seek professional advice on the
economic aspects of horse breeding. Taken as a whole, these
facts do not persuade us that the activity had a profit motive.
Elements of Personal Pleasure
The absence of personal pleasure or recreation relating to
the activity in question may indicate the presence of a profit
objective. Sec. 1.183-2(b)(9), Income Tax Regs. The mere fact
that a taxpayer derives personal pleasure from a particular
activity does not, per se, demonstrate a lack of profit motive.
Petitioner stipulated that he derived personal pleasure and
enjoyment from the horse breeding activity. Based on the facts
of this case, we find that this factor weighs against petitioner.
Time and Effort Expended by Petitioner
Petitioner spent a significant amount of time on the horse
breeding activity; however, he also stipulated that he received
pleasure from the horse breeding activity. Where an activity has
substantial personal or recreational aspects, the time and effort
spent may be due to a taxpayer's enjoyment of the activity rather
than an intent to derive a profit. White v. Commissioner, 23
T.C. 90, 94 (1954), affd. per curiam 227 F.2d 779 (6th Cir.
1955). Although enjoying an activity does not preclude a profit
objective, the facts of this case suggest that petitioner spent
time on the activity due to his fondness for horses rather than
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