Nicholas M. Romer - Page 13

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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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