- 21 -
T.C. at 274; Sullivan v. Commissioner, T.C. Memo. 1998-367; Dodge
v. Commissioner, T.C. Memo. 1998-89; Taras v. Commissioner, T.C.
Memo. 1997-553.
The only evidence in the record of petitioners’ horses’
appreciation consists of Dr. Hillman’s self-serving,
uncorroborated estimates. No expert or other reliable evidence
of value was introduced. Given that Dr. Hillman reported on his
1994 return that Ashley, a mare purchased 10 years earlier for
$2,500 that suffered chronic uterine infections and had been
donated to a veterinary school with a euthanasia authorization,
had a fair market value of $4,800, we do not believe his
estimates are entitled to significant weight.7 Even if we
accepted Dr. Hillman’s value estimates, the appreciation
experienced as of 1993--approximately $33,000, using his
estimates--falls significantly short of petitioners’ accumulated
losses through 1993, which exceeded $51,000. Losses in excess of
$17,000 occurred in each of the two succeeding years.
Petitioners have failed to show that the appreciation in value of
their assets creates any inference of profit motive.
7 In addition, Dr. Hillman’s asking price for Chicardo was
$3,500, but the horse was ultimately sold for $1,800.
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011