- 18 - 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 adequatePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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