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and sufficient explanation for the hard work and losses
undertaken by petitioners.”); King v. Commissioner, T.C. Memo.
1993-237 (“Moreover, the fact that running the horse farm was
hard work does not negate the pleasure petitioner received from
owning the horses.”); Feldman v. Commissioner, T.C. Memo.
1986-287 (“Like businesses, recreational pursuits are at times
tedious and unpleasant. Petitioners and their family enjoyed
activities involving horses, and we believe that they were
willing to muck stalls and perform other unappealing tasks as the
price for their enjoyment.”).
Inasmuch as petitioners had no possibility of earning a
financial profit from their horse-breeding activity in the manner
they conducted it, we see no reason for them to have engaged in
the activity except for pleasure of some kind. One person may
find pleasure in what another considers to be unpleasant physical
labor. Even if petitioners found certain aspects of the activity
to be unpleasant, the pleasurable aspects of raising horses must,
for petitioners, have outweighed the unpleasant “backbreaking”
work. Otherwise, petitioners would not have engaged in the
activity in the first place and would have discontinued the
activity long ago. We need not try to engage in parlor
psychoanalysis to explain their motivation for engaging in the
horse-breeding activity when the facts show that they were not
motivated primarily by profits.
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