Robert Bryan Hudnall and Victoria A. - Page 9




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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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