- 14 - 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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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