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with Docs Fancy Feat, petitioners have not cited any mishaps that
have interfered with Colonel Rey Lew's career. Petitioners have
failed to demonstrate how additional time in competition is
likely to change Colonel Rey Lew's value dramatically. As to
petitioners' contention that Colonel Rey Lew's value will rise if
his offspring are successful, we note that petitioners at trial
were not even certain of the number of his offspring. Beyond
bare speculation, petitioners have failed to show that Colonel
Rey Lew's value is likely to appreciate dramatically beyond their
current estimate. While their current estimate represents
substantial appreciation, it falls short of recouping their
losses. As a result, the anticipated appreciation in value of
petitioners' assets is insufficient to create an inference of
profit motive. Golanty v. Commissioner, 72 T.C. 411, 427-428
(1979); cf. Dodge v. Commissioner, T.C. Memo. 1998-89; Taras v.
Commissioner, supra.
Past Success in Similar or Dissimilar Activities
A taxpayer's past success in similar or dissimilar
activities is relevant in determining profit motive. Sec. 1.183-
2(b)(5), Income Tax Regs.
It has been stipulated that in 1992 petitioners' horse-
related activity was predominantly operated by Mrs. Sullivan, and
that Mr. Sullivan worked 80 to 100 hours per week in his job as
an investment manager. Given the demands of Mr. Sullivan's job
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