- 22 -
conducting the activity for profit. See sec. 1.183-2(b)(9),
Income Tax Regs. However, a taxpayer's enjoyment of an activity
does not show that the taxpayer lacks a profit objective if the
activity is conducted for profit as shown by other factors. See
Jackson v. Commissioner, 59 T.C. 312, 317 (1972); sec. 1.183-
2(b)(9), Income Tax Regs. Petitioners enjoyed breeding and
showing horses, but we doubt that petitioners’ motive for
boarding and leasing their horses to others was to derive
personal pleasure. This factor is neutral.
C. Conclusion
Petitioners operated their horse activity in a business-like
manner. They had the expertise to conduct a profitable horse
activity. They spent a substantial amount time on their horse
activity, including taking care of other people’s horses. We
conclude that petitioners engaged in their horse activity for
profit in 1995 and 1996.
To reflect the foregoing,
Decision will be entered
for petitioners.
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Last modified: May 25, 2011