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in value; (5) the success of the taxpayers in carrying on other
similar or dissimilar activities; (6) the taxpayers' history of
income or loss with respect to the activity; (7) the amount of
occasional profits that are earned; (8) the financial status of
the taxpayers; and (9) whether elements of personal pleasure or
recreation are involved. No single factor is controlling, and we
do not reach our decision by merely counting the factors that
support each party's position. See Dunn v. Commissioner, 70 T.C.
715, 720 (1978), affd. 615 F.2d 578 (2d Cir. 1980); sec. 1.183-
2(b), Income Tax Regs. Rather, the relevant facts and
circumstances of the case are determinative. See Golanty v.
Commissioner, supra at 426.
After considering all the factors, we agree with respondent
that petitioners did not have an actual and honest objective of
making a profit because: (1) Petitioners enjoyed substantial
personal pleasure and recreation from their horse-related
activities; (2) they did not have any experience or expertise in
operating a horse-related business; (3) petitioners' clientele
remains unverified; and, (4) petitioners did not carry on their
activities in a businesslike manner. See sec. 1.183-2(b), Income
Tax Regs. Moreover there is no indication that petitioners had
any chance of recovering the loss they suffered. See Bessenyey
v. Commissioner, 45 T.C. 261, 274 (1965), affd. 379 F.2d 252 (2d
Cir. 1967); sec. 1.183-2(b)(4), Income Tax Regs.
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