- 13 - amount of occasional profits, if any, which are earned; (8) the financial status of the taxpayer; and (9) whether elements of personal pleasure or recreation are involved. After considering the above factors, we find that petitioner has not proved that he was engaged in his horse selling and leasing activity with the requisite profit objective necessary to support deductions under sections 162 or 212(1) and (2). We are not convinced that petitioner's experience in training horses ever involved more than his use of them for his own personal recreation. He admits that he spent only a few hours each week on this activity and that part of this time was spent demonstrating his competence as a polo player to the members of the Nashville Polo Club. Although he testified that his intention was to make a profit by selling horses, we find that the objective facts in this case show that he never made the kind of commitment to the activity that would have given him a reasonable chance to make a profit. We hold that petitioner is not entitled to a business loss deduction with respect to his horse selling and leasing activity. Respondent's determination on this issue is sustained. The third issue for decision is whether expenses paid by petitioner in connection with his aviation activity are deductible as ordinary and necessary business expenses. On a single Schedule C attached to his 1993 return, petitioner labeled his various aviation activities, other thanPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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