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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 than
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