Richard J. and Melodie D. McKeever - Page 31




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                  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.                                  






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