Fred B. and Georgia Elane Berry - Page 21




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            for gratification, the latter possibility may be the primary                               
            motivation for the activity.  See White v. Commissioner, 23 T.C. 90,                       
            94 (1954), affd. per curiam 227 F.2d 779 (6th Cir. 1955).                                  
            Petitioners point out that no person in their family rode horses for                       
            pleasure in the year in issue.  However, Mrs. Berry testified that                         
            she has always enjoyed horses.  This factor is neutral.                                    
            D.    Conclusion                                                                           
                  We conclude that petitioners did not operate their farm and                          
            horse-breeding activity for profit in 1995 for purposes of section                         
            183.3                                                                                      
                  The record contains information about events that occurred                           
            after 1995, on which both parties rely.  The post-1995 information                         
            shows that the pre-1995 pattern of activity and losses generally                           














                  3  Some of petitioners’ activities may have been for profit,                         
            such as those involving their crops and the hauling and boarding                           
            of horses.  However, petitioners do not contend that they had                              
            more than one activity, and they have not provided any basis for                           
            us to decide the amount of their expenses that were related to                             
            activities that may have been for profit.                                                  





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