- 15 - sought no professional advice on the economic aspects of the breeding, training, and showing of Arabian horses. Petitioner is an intelligent person, and he has acquired a good deal of knowledge about Arabian horses and their breeding. However, such activity and knowledge are altogether consistent with his interest in a hobby, and he has failed to show that he sought or acquired the expertise that would enable him to turn the activity into a profitable business. (3) The Time and Effort Expended by the Taxpayer in Carrying on the Activity. Petitioner argues that he has organized his medical practice and his farm so that he can spend enough time to develop his Arabian horse activity. Petitioner devoted substantial time to his medical practice. The time and effort spent breeding horses was substantially less and was not inconsistent with the time one might expect to be devoted to a hobby from which the participant receives enjoyment and satisfaction. (4) Expectation That Assets Used in Activity May Appreciate in Value. Petitioner argues that he expects the assets used in his activity will appreciate in value. Petitioner did not estimate the value of his horses, and no expert testimony or other reliable evidence of value was introduced. Based on petitioner’s reported sales of Arabian horses to date, he does not come close to covering his losses.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011