- 13 - operation was too small for that. It does not appear that Midget Acres had a separate bank account. We find that petitioners did not conduct this activity in a businesslike manner. 2. Expertise of Petitioners Preparation for an activity by extensive study or consultation with experts may indicate a profit motive where the taxpayer conducts the activity in accordance with such study or advice. See sec. 1.183-2(b)(2), Income Tax Regs. Petitioner has a long history with horses. Both petitioners have worked with horses, and petitioner especially has great knowledge and experience about bloodlines and with raising, training, showing, and breeding of various types of horses. Petitioners also spent quite a few years working for horse farms where they observed operations. Petitioner often helped out friends and business associates with the purchase of racing horses. Petitioner testified that she sought advice from Robert Hundley who was a trainer as Santa Anita Hollywood Park and a breeder of thoroughbred horses. However, petitioner did not testify as to the kind of advice sought nor the nature of the advice received. While petitioners have excellent credentials for horse breeding, training, and racing, it is not clear whether they were experienced or sought advice with regard to the financial aspects of operating a horse business. 3. Time and Effort Spent in Conducting Activity The fact that the taxpayer devotes much of his or her personal time and effort to carrying on an activity, particularlyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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