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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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