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for the horses,7 such as cleaning stables, as well as her arduous
schedule of attending horse shows most weekends, was too
unpleasant to constitute a hobby.
With respect to Mrs. Sullivan's schedule of weekend horse
shows, records have only been provided for 1992. A portion of
Mrs. Sullivan's attendance at shows that year was for the purpose
of competing on Miss Doc Chic, a horse in which petitioners did
not retain any possibility of profit. Their prize stallion
Colonel Rey Lew, on which their argument of profit motivation is
staked, was being ridden in competition by someone else in 1992.
Nevertheless, even if we accept that Mrs. Sullivan traveled
to an extensive number of weekend horse shows that year and
provided the manual labor required to care for the horses kept on
petitioners' premises, we have some difficulty with petitioners'
argument that Mrs. Sullivan's time and effort were too extensive
to be other than profit-oriented. The regulations effectively
provide that time and effort are somewhat discounted as a factor
when the activity has substantial recreational aspects. Keeping
7 Petitioners exaggerate somewhat the labor expended by Mrs.
Sullivan. While petitioners on brief repeatedly invite us to
contemplate the rigors of cleaning stables, etc., for seven, or
seven to nine, horses, the record demonstrates that in 1992,
petitioners owned six horses, two of which were kept at Mr.
Hightower's farm. The record further reveals that an individual
was compensated during 1992 to exercise at various times two of
the four horses kept on petitioners' premises. Nonetheless, we
accept that Mrs. Sullivan provided significant manual labor in
caring for the horses kept on petitioners' premises.
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