Joyce E. Hastings - Page 16




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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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