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attempted breeding deal did not materialize as planned. As in
prior years, petitioner made no attempt to cut her overhead or
losses by ridding herself of unproductive horses or limiting her
acquisitions to horses that furthered a profit-making objective.
Rather, in 1993, petitioner purchased three broodmares and a
gelding even though these horses could not produce stud fees.
Based on the above considerations, petitioner did not
operate her horse activity in a businesslike manner in 1993.
This factor fails to indicate a profit objective.
2. The expertise of the taxpayer or his advisers.
In considering this factor, the focus is upon expertise and
preparation with regard to the economic aspects of the particular
activity, and failure to possess or obtain expertise in this area
will not be excused by study of other aspects of the activity or
by general business acumen. See, e.g., Golanty v. Commissioner,
72 T.C. at 432.
Petitioner is bereft of the requisite economic expertise.
Although petitioner consulted experts on how to generate income
from horse activities before she began her horse activity, she
does not claim to have consulted with any economic or financial
experts during her operations, even when faced with mounting
losses. This factor does not indicate a profit objective.
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