- 31 - Finally, we note that none of the changes made by petitioners, ostensibly to reduce losses, control costs, and foster profitability, had any material effect. The amount of petitioners’ losses did not decline following the move to the ranch, despite petitioners’ claims that the move enabled them to perform ranch work and otherwise minimize expenses. The emphasis on new bloodlines did not result in any significant reduction in net losses. Under the facts and circumstances of this case, “the trappings of a business” that exist are insufficient to demonstrate that petitioners’ horse activity was carried on in a businesslike manner for profit. See Golanty v. Commissioner, 72 T.C. at 430. On balance, we conclude that petitioners did not operate their horse activity in a businesslike manner. This factor favors respondent’s position. 2. The Expertise of Petitioners or Their Advisers Preparation for an activity by extensive study of its accepted business, economic, and scientific practices, or consultation with industry experts, may indicate a profit motive where the taxpayer carries on the activity in accordance with such practices. See sec. 1.183-2(b)(2), Income Tax Regs. Petitioners argue that Mrs. McKeever’s background as a lifelong horsewoman provided sufficient expertise to indicate a profit motive. We disagree. We do not intend to denigrate Mrs.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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