- 21 - 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.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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