- 35 - elements involved. Sec. 1.183-2(b)(8), Income Tax Regs. Mr. Sullivan's earnings from his employment as an investment manager were $108,750 in 1992 and never less than $90,000 annually from 1989 through 1995. Clearly, Mr. Sullivan's employment income allowed petitioners to sustain annual losses from their horse-related activities averaging $40,000 during these years. Deducting these losses significantly reduced the after-tax cost of such activities to petitioners. Cf. Golanty v. Commissioner, supra at 429; Osteen v. Commissioner, T.C. Memo. 1993-519. When combined with the recreational elements present for Mrs. Sullivan, we believe the after-tax economics of petitioners' horse-related activities support an inference that they were not engaged in for profit. Personal Pleasure or Recreation The existence of recreation elements in the activity may indicate the activity is not engaged in for profit; conversely, where an activity lacks any appeal other than profit, a profit motivation may be thereby indicated. Sec. 1.183-2(b)(9), Income Tax Regs. The record in this case amply supports a finding that Mrs. Sullivan's recreational objectives were a significant component of petitioners' horse-related activities. As noted, Mrs. Sullivan has been actively pursuing an interest in horses since she was 14, rode while in high school and college, and afterPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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