- 44 - horse activity, this tax benefit resulting from the activity does not prove the absence of a profit motive. See Engdahl v. Commissioner, 72 T.C. at 670. It is, however, a factor to be considered. See Golanty v. Commissioner, 72 T.C. at 429. The size of the horse-related expenditures in comparison to petitioners’ adjusted gross income is substantial. In 1991, 1992, and 1993, petitioners reported wage income of $141,724, $148,169, and $171,379, respectively. During those same years, the horse activity lost $55,843, $70,598, and $64,886, respectively. Petitioners argue that the level of expenses compared to their gross income favors their position since the amount is more than one normally would spend on a mere hobby. Respondent asserts that the substantial tax benefits, coupled with the enjoyment petitioners derived from their horses, suggest the activity was not engaged in for profit. We think there is some truth to both parties’ assertions, but we do not fully agree with either party. This factor does not favor either party’s position in our analysis. 9. Elements of Personal Pleasure or Recreation The existence of personal pleasure or recreation relating to the activity may indicate the absence of a profit objective. See sec. 1.183-2(b)(9), Income Tax Regs.Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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