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for her horse activity. Since petitioner’s horse activity was in
the startup phase for the year in issue, this factor is neutral
as to whether petitioner had a profit objective.
7. The amount of occasional profits, if any, which are
earned.
As indicated above, petitioner has earned no profits from
her horse activity, so this factor does not support a profit
objective.
8. The financial status of the taxpayer.
Petitioner used the losses from the horse activity to reduce
her taxable income by offsetting income from her law practice.
Petitioner claims to have been in the process of reducing the
size of her law practice during 1993. Due to her underreporting
of income from the law practice, as discussed above, it is
unclear whether petitioner actually reduced the size of her law
practice in 1993. Petitioner reported income from her law
practice that was almost completely offset by losses claimed from
the horse activity. This factor does not indicate a profit
objective.
9. Elements of personal pleasure or recreation.
Petitioner derived substantial personal pleasure from her
horse activity. We have no doubt that petitioner worked hard in
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