- 34 -
Although someone was hired to clean stalls, petitioners fed their
horses twice daily, washed, clipped, or groomed their horses
daily, and exercised, conditioned, and trained their horses 4
days a week. Mrs. McKeever also kept the books and paid bills
associated with the activity.
Subsequent to their move to the ranch in mid-1991,
petitioners spent substantially all their free time on their
horse activity. Although respondent argues that petitioners
failed to establish the number of hours per week engaged in the
horse activity, the stipulated facts confirm that petitioners
must have spent considerable time and effort on mundane tasks
pertaining to their horse activity.
The time and effort expended by petitioners on their horse
activity supports their contention of profit motivation.
Although petitioners love their horses and enjoy the work
associated with the activity, many duties performed in connection
with the activity do not have recreational aspects, such as
feeding, washing, and worming the animals. Although some tasks,
such as showing horses and riding in parades, have recreational
aspects, on balance we conclude that petitioners’ time and effort
favor their contention that the activity was engaged in for
profit. See sec. 1.183-2(b)(3), Income Tax Regs.
This factor favors petitioners’ position.
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