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Petitioners argue that the only pleasurable aspect
regarding their horse activity was riding in horse shows and
parades. Petitioners also argue that Mrs. McKeever saw the horse
activity as a way to exit the field of hematology, from which she
fears contracting a blood-borne illness. Finally, petitioners
argue that the size of their herd indicates that they are in the
horse business for profit, not pleasure. Respondent asserts that
both petitioners enjoy riding horses and that the horses provide
a social outlet for them, noting petitioners’ involvement in
parades and horse shows. Respondent points to the fact that paso
finos were chosen, in part, so that Mr. McKeever would be able to
ride despite his back problems. Respondent also notes Mr.
Minter’s testimony regarding the purpose for which Flint Oak Aura
was purchased and cites petitioners’ E-mail address
(Pasolove@aol.com) as evidence of petitioners’ emotional
attachment to their horses.
We agree with respondent that substantial elements of
personal pleasure and recreation are present in petitioners’
horse activity. However, “We also note that a business will not
be turned into a hobby merely because the owner finds it
pleasurable; suffering has never been made a prerequisite to
deductibility. ‘Success in business is largely obtained by
pleasurable interest therein.’” Jackson v. Commissioner, 59 T.C.
312, 317 (1972) (quoting Wilson v. Eisner, 282 F. 38, 42 (2d Cir.
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