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residence to his medical office was 12 miles one way. Dr.
Hillman estimated his business mileage by subtracting 24 miles on
4 days of each week (representing one round trip between his
residence and medical office for each day he maintained office
hours) from the total change in miles on his odometer for the
year. In this manner, Dr. Hillman estimated business mileage of
24,368 miles and 28,027 miles for 1993 and 1994, respectively,
which he provided to Mr. Adelman. In respondent’s determination,
these mileage figures were reduced to 12,987 and 14,854,
respectively.
OPINION
I. Horse-Related Activities
The first issue to be resolved is whether petitioners’
activities involving the breeding and showing of horses
constituted an activity not engaged in for profit.2 As a general
rule, individuals are not allowed to deduct losses attributable
to an activity “not engaged in for profit”, except to the extent
2 The parties have treated all of petitioners’ horse-related
activities as a single activity for purposes of sec. 183, see
sec. 1.183-1(d)(1), Income Tax Regs., which we refer to as the
show horse activity, consistent with petitioners’ usage on their
returns.
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