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horses, which he realized required a considerable amount of
money.
Petitioner testified that his long-term goal was to produce
English competition horses19 that were capable of competing and
winning at the national level in the English division and that
could produce the same type of offspring. According to
petitioner, he has been very successful in reaching his goal of
producing horses that could successfully compete at the national
level. He testified that his horses have won nine national
championship honors. Petitioner testified that his ultimate goal
is to retire from medicine young enough so that he is still able
to work and participate in the management of his horses, ride
them, compete with them, and eventually sell them.
Petitioner argues that his substantial time commitment and
hard work eliminate any elements of pleasure or recreation. We
recognize that the level of work or effort may indicate a profit
objective and that caring for horses and maintaining a horse farm
are hard work. However, the fact that an activity involves hard
work does not, standing alone, establish that an activity was
engaged in primarily for profit. Petitioner’s introduction into
horse breeding was precipitated by his love of horses, and he
enjoyed his horse-related activity. Of course, the enjoyment of
19Arabian horses compete in English competition, which is a
division of the competitions within the Arabian horse shows.
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