- 24 - assets exceeds the operating losses. Id. The appreciation in value must be sufficient, however, to recoup the accumulated losses of prior years. Golanty v. Commissioner, supra at 427- 428; Bessenyey v. Commissioner, 45 T.C. at 274; Dodge v. Commissioner, supra; Taras v. Commissioner, T.C. Memo. 1997-553. Petitioners incurred operating losses in 23 of the 26 years in which they have been engaged in their horse-related activities. For 16 of the loss years, the amount of the loss is not available. For the remaining 7 loss years, which are the most recent 7 years through 1995, accumulated losses total $279,270. Even accepting arguendo petitioners' own estimates of the value of their horses in 1996, such estimates are in a range of $170,000 to $222,500. Thus the appreciated value of petitioners' horses, by their own estimate, does not recoup the losses of the last 7 years, let alone the accumulated losses of the other 16 loss years. Nor do we think there is reason to believe that future appreciation will recoup petitioners' losses. Petitioners estimated that Colonel Rey Lew, their current prize stallion, was worth $100,000 to $150,000 in 1996, and they offered speculation that he had tremendous potential yet to be realized. We are not persuaded by such speculation. The horse has been old enough to compete since 1989 and has achieved significant success in both professional and nonprofessional competition since that time. As distinguished from the situationPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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