Louis J. Novak - Page 14




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          winnings.  Petitioner’s participation in shows and equestrian               
          events is as consistent with a hobby as it is a business.  See              
          Golanty v. Commissioner, 72 T.C. 411, 430 (1979), affd. without             
          published opinion 647 F.2d 170 (9th Cir. 1981).                             
          (2) The Expertise of the Taxpayer or His Advisers.                          
               Petitioner argues that he became an expert in the Arabian              
          horse-breeding business, read numerous periodicals pertaining to            
          Arabian horses, participated in various Arabian horse-related               
          organizations, and consulted with individuals whom petitioner               
          considered to be experts in the field.  The mere fact that                  
          petitioner has skill in the breeding of horses and hired various            
          experts does not prove that petitioner was engaged in his horse             
          activity primarily for profit.  See Glenn v. Commissioner, T.C.             
          Memo. 1995-399, affd. without published opinion 103 F.3d 129 (6th           
          Cir. 1996).  Expertise with respect to the breeding of horses is            
          to be distinguished from expertise in the economics of these                
          undertakings.  See id.; see also Golanty v. Commissioner, supra             
          at 432.  A taxpayer's failure to obtain expertise in the                    
          economics of horse-related activities indicates a lack of profit            
          motive.  See Burger v. Commissioner, 809 F.2d 355, 359 (7th Cir.            
          1987), affg. T.C. Memo. 1985-523.  In this case, petitioner                 




               12(...continued)                                                       
          $3,452, $3,250, and $3,625, respectively.                                   





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