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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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