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The weight and credibility of the evidence presented
suggests that petitioners may have accepted some income for the
use of their farm which defrayed the cost of their recreational
horse-related activities. Still, the expectation of profit was
lacking.
Petitioners enjoyed substantial personal benefits from the
use of the farm, but that, by itself, does not preclude their
activities from being "for profit". See Jackson v. Commissioner,
59 T.C. 312, 317 (1972). However, the presence of personal
motives may indicate that the activity is not engaged in for
profit. See Glenn v. Commissioner, T.C. Memo. 1995-399, affd.
without published opinion 103 F.3d 129 (6th Cir. 1996).
When petitioners moved to Maryland and rented the farm at
issue, they saved themselves the cost of boarding their own
horses elsewhere and had greater access to the horses for their
daughters. Petitioners' testimony describes activities which did
not exceed what would be necessary to care for their own horses.
Barns and stables were renovated. Family members helped in
exchange for meals. Mrs. Hudnall cleaned stables. These
activities do not go beyond those related to the care of one's
own horses.
Petitioners did not produce credible evidence that the
horse-related activity had a chance of recovering the losses it
had incurred. See Bessenyey v. Commissioner, supra at 274. The
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