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Golanty v. Commissioner, 72 T.C. at 432. A taxpayer’s failure to
obtain expertise in the economics of horse-related activities
indicates a lack of profit motive. See Burger v. Commissioner,
supra at 359. In this case, petitioners sought no professional
advice on the economic aspects of the breeding and showing of
horses. Dr. Hillman’s discussions with his accountant focused on
the tax aspects of petitioners’ show horse activity.
Time and Effort Expended
The fact that the taxpayer devotes much of his or her
personal time and effort to carrying on an activity, particularly
if the activity does not have substantial recreational aspects,
may indicate a profit motive. See sec. 1.183-2(b)(3), Income Tax
Regs. Dr. Hillman testified that he spent “something over 500
hours” attending horse shows in 1993, and that the bookkeeping
tasks associated with the show horse activity took approximately
2 to 3 hours per month. Dr. Hillman’s testimony regarding time
spent at horse shows is self-serving, uncorroborated, and not
credible. The parties have stipulated that none of petitioners’
horses participated in horse shows in 1993. Even putting aside
this inconsistency, Dr. Hillman’s estimate of “over 500 hours”
appears scripted to meet respondent’s alternative argument that
the show horse activity was a section 469 “passive activity”,
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