Barry S. and Yvonne C. Hillman - Page 18

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               Overall, the numerous unbusinesslike practices engaged in by            
          petitioners provide strong evidence of a lack of profit motive.              
          Expertise of Petitioners and Their Advisers                                  
               Preparation for an activity by extensive study or                       
          consultation with experts may indicate a profit motive where the             
          taxpayer conducts the activity in accordance with such study or              
          advice.  See sec. 1.183-2(b)(2), Income Tax Regs.  The record                
          demonstrates that Dr. Hillman was involved with horses for 40                
          years and had become quite knowledgeable in the breeding of                  
          horses.  Petitioners have also spent considerable sums to employ             
          professional trainers for their horses (although as noted some of            
          the trainers’ time was spent instructing petitioners’ daughter).             
          Dr. Hillman testified that he consulted with others concerning               
          the purchase of horses and delegated actual purchasing to them.              
               However, the mere fact that Dr. Hillman had skill in the                
          breeding of horses and petitioners hired various experts does not            
          prove that petitioners engaged in their show horse activity for              
          profit.  See Glenn v. Commissioner, T.C. Memo. 1995-399, affd.               
          without published opinion 103 F.3d 129 (6th Cir. 1996).                      
          Expertise with respect to the breeding and showing of horses is              
          to be distinguished from expertise in the economics of these                 
          undertakings.  See, e.g., Burger v. Commissioner, 809 F.2d 355,              
          359 (7th Cir. 1987), affg. T.C. Memo. 1985-523; Sullivan v.                  
          Commissioner, supra; Glenn v. Commissioner, supra; see also                  

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