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(8) The Financial Status of the Taxpayer
At the time petitioner purchased the property in 1986, he
had wage income of $156,461. His income remained above the six-
figure mark through 1997. Petitioner’s average wage income from
1986 through 1997 was $215,884. During the years in issue,
petitioner also earned $59,897 from University Imaging.
Petitioner was single, had a substantial income, and could afford
to spend money on an activity that gave him enjoyment.
(9) Elements of Personal Pleasure or Recreation
If the possibility for profit is small compared to the
possibility for gratification, the latter possibility may be the
primary motivation for the activity. See White v. Commissioner,
23 T.C. 90, 94 (1954), affd. per curiam 227 F.2d 779 (6th Cir.
1955).
Petitioner’s recreational objectives were a significant
component of his horse-related activities. Petitioner testified
that when he was in college and trying to decide on a vocation,
he told his father that he was considering becoming a school
teacher. According to petitioner, his father gave him the
following advice: “[I]f you ever want to have horses, you can’t
be a school teacher, you’ve got to find a job where you can make
some money, be a doctor or a dentist”. Based on his father’s
advice, petitioner decided to go to medical school so that he
could make a decent living and continue to do something with
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