- 20 -                                         
                    e.     Change of Operating Methods                                
               A willingness to adopt new techniques or abandon                       
          unprofitable methods may indicate that a taxpayer has a profit              
          motive.  Sec. 1.183-2(b)(1), Income Tax Regs.                               
               Petitioner changed her plans for Temptation and Labrette.              
          She stopped entering Temptation in competitions because he was              
          lame.  However, she did not adopt a new technique for becoming              
          profitable because she was already breeding Temptation.  In fact,           
          petitioner continued to breed Temptation even though the two                
          foals produced by Temptation before the years in issue were far             
          below her expectations.                                                     
               Petitioner changed her plan from breeding Labrette to                  
          competing her.  Petitioner contends that Labrette's success could           
          help her horse breeding activity become profitable, but we are              
          not convinced that she compared the expenses with the profit                
          potential.  This suggests she cared about sports success, not               
          business success.                                                           
               Petitioner testified that petitioners moved to Florida, and            
          then relocated in Florida, to be near dressage activities.                  
          Petitioners also point out that petitioner culled her herd in               
          1987 when she donated three thoroughbred mares to a Gainesville             
          breeding program.  However, petitioner did not show how these               
          changes would make her horse breeding activity profitable.                  
                    f.     Advertising                                                
               The record includes copies of six advertisements for                   
          Serenity Farms and Temptation that petitioner placed before the             
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