Louis J. Novak - Page 22




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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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