- 9 - if so how, the activity could be operated profitably or to make informed business decisions on a periodic basis. During his investigation of horse breeding, Dr. Harrington was told by professional breeders that it would be difficult to make a profit from breeding Appaloosa horses. The economics of petitioners’ operation showed that they could not make a profit from their horse-breeding activity. Petitioners consistently incurred expenses of more than $10,000 per year. Breeding their stallion only two or three times per year would yield at best only two or three foals per year (horses have an 11-month gestation period), worth at most $7,500 in the unlikely event that all three foals had Appaloosa characteristics. Petitioners’ horse-breeding activity was a money-losing proposition without hope of success. Citing Engdahl v. Commissioner, 72 T.C. 659 (1979), petitioners argue that because Dr. Harrington did most of the work himself, and that much of this work was not pleasurable, he should be deemed to have engaged in the activity in a businesslike way. We disagree. In Engdahl, after Dr. Engdahl’s retirement as an orthodontist, the Engdahls purchased a ranch to breed American saddle-bred horses after receiving professional advice on operating the ranch profitably. Due to unexpected adverse market conditions, the ranch was not profitable. The Court found that the Engdahls operated their business in the samePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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