Julius Lee Harrington and Mary Lou Ziter - Page 19




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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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