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1992, no deficiency in income tax resulted for any of those years
because of the aforementioned NOL in 1990 attributable to
petitioner's accounting practice.
Respondent disallowed the losses claimed by petitioner from
the horse activity on the ground that such activity was not
pursued with the requisite profit objective. See secs. 162(a),
212, 183; see also Dreicer v. Commissioner, 78 T.C. 642, 645
(1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983).
In determining that petitioner’s horse activity was not
conducted with the requisite profit objective, respondent relied
on findings in the revenue agent’s report (RAR), including, in
particular, the following: (a) That petitioner did not maintain a
formal business plan or prepare projections on profitability or
consider stop-loss points, that petitioner estimated losses, and
that petitioner did not maintain accurate books and records of
the activity, see sec. 1.183-2(b)(1), Income Tax Regs.; (b) that
petitioner did not invest a significant amount of time and effort
in the horse activity, relying in part on the fact that
petitioner also owned and operated an accounting firm and owned
and managed two rental properties, see sec. 1.183-2(b)(3), Income
Tax Regs.; (c) that EIP did not own any assets with the potential
to appreciate in value sufficient to overcome the losses
sustained in the activity, see sec. 1.183-2(b)(4), Income Tax
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