Roderick P. Strickland and Linda G. Strickland - Page 16




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          in their child’s horse show activity than in making a profit).              
          We disagree.  The taxpayers in that case had no experience with             
          horses before they began their horse activity.  The taxpayers’              
          son began competing 3 years before they began their horse                   
          activity.  He showed great potential as a rider the year before             
          they started the activity.                                                  
               Respondent contends that petitioners’ failure to own a                 
          stallion was inconsistent with their business plan and restricted           
          their ability to make a profit.  We disagree.  Petitioners did              
          not own a stallion because that would require them to pay to                
          acquire and maintain the stallion and to modify their facilities.           
               Respondent contends that petitioners’ mares were not good              
          enough to support a profitable breeding program.  It was too                
          early to tell whether respondent’s speculation is correct in 1995           
          and 1996, the third and fourth years of petitioners’ horse                  
          breeding activity.                                                          
               Respondent contends that petitioners did not advertise their           
          horse activity in a businesslike manner.  We disagree.                      
          Petitioners advertised horses for sale in a local newspaper.                
          They also showed their horses.  See Engdahl v. Commissioner, 72             
          T.C. at 662-663, 667 (“Horse shows are the best form of                     
          advertising for American saddle-bred horses.”); Golanty v.                  
          Commissioner, 72 T.C. 411, 430-431 (1979) (taxpayers’ failure to            
          show horses indicated that taxpayers were not engaged in activity           






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