Louis J. Novak - Page 15




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          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.                                                     






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