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Petitioner did not establish that he purchased the real
estate in Newbury, Ohio, with appreciation in mind, nor did he
hold the property primarily with appreciation in mind.
Petitioner testified that he intended to live and retire on the
property. It was something that he wanted to keep. He did not
express any desire to sell or profit from the property in order
to offset or recoup his losses.
Petitioner lived on the Newbury, Ohio, property. To the
extent there was any appreciation, much of it could have been
attributable to the house that petitioner lived in. Based on
this record, we are unable to separate the property used for the
breeding, training, and showing of Arabian horses from
petitioner’s residential property.
(5) The Success of the Taxpayer in Carrying on Other Similar or
Dissimilar Activities.
Petitioner has been quite successful as a doctor and was a
shareholder in a profitable S corporation. Petitioner reported
income totaling $59,897 from University Imaging during the years
in issue. On the other hand, petitioner was not successful in
his horse partnership Amanda Associates. Petitioner reported
$16,900 in losses relating to the partnership on his Federal
income tax returns from 1986 through 1990.13
13Petitioner had an interest in the partnership until 1990.
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