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rejected the taxpayer’s argument that the hard work involved in
breeding horses establishes that the activity was engaged in for
profit.
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. * * *
Id.; see also Surridge v. Commissioner, T.C. Memo. 1998-304 (“the
fact that running the horse farm was hard work does not negate
the pleasure petitioners received from engaging in the horse
activity”); Yates v. Commissioner, T.C. Memo. 1996-499 (“while we
do not reject petitioners’ contention that” “* * * maintenance of
horses demand a large measure of laborious and unpleasant work”.
“* * * [We] also believe that petitioners were partially
motivated by personal reasons in engaging in the horse-breeding
activities”), affd. without published opinion 163 F.3d 609 (9th
Cir. 1998); Bischoff v. Commissioner, T.C. Memo. 1995-34 (“While
we agree that the training and breeding of horses is hard
physical work, it is clear from the facts in this case that
petitioner enjoyed this activity and lifestyle.”); Borsody v.
Commissioner, T.C. Memo. 1993-534 (“We cannot conclude that the
virtues of farm life and the show ring do not provide an adequate
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