- 28 - competition and that this weighs against finding that he engaged in the horse activity for profit. We disagree. Petitioners and their family did not ride their horses for pleasure. Petitioner does not enjoy all the driving required to participate in horse shows or to go to McDannald’s to train petitioners’ horses. Petitioners showed their horses at horse shows as their primary method of advertising. There is a high correlation between success in horse shows and success in the marketplace. See Appley v. Commissioner, T.C. Memo. 1979-433; cf. Engdahl v. Commissioner, supra at 667; Golanty v. Commissioner, supra at 431 (taxpayers’ failure to show horses indicated that taxpayers were not engaged in activity with a profit objective). Petitioners do not deny that they enjoyed many aspects of the horse activity. The fact that petitioners enjoyed the horse show competitions does not mean that they did not conduct their horse activity for profit. See Harvey v. Commissioner, T.C. Memo. 1988-13. This factor favors petitioners. 10. Conclusion Considering petitioner’s testimony as corroborated by the record as a whole, particularly the time and effort petitioners spent on the activity, petitioners’ reasonable expectation of profit from appreciation of the assets used in the activity, petitioner's business plan, and the startup nature ofPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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