- 20 - indicative of a profit objective. Sec. 1.183-2(b)(2), Income Tax Regs. The fact that Mrs. Reimer had experience in raising or maintaining horses prior to entering into the horse breeding activity does not alone show that the horse activity was engaged in with a profit objective. See Glenn v. Commissioner, T.C. Memo 1995-399, affd. without published opinion 103 F.3d 129 (6th Cir. 1996). At the time they started the activity, petitioners owned J-Mar Elbravado, which introduced them to the business of Arabian horse breeding. Petitioners also sought general advice from other breeders, trainers, and an accountant. However, there is no evidence that they reviewed the records of other breeding operations or sought specific advice as to how to make their operation profitable. Similar to the taxpayers in Burger v. Commissioner, T.C. Memo. 1985-523, affd. 809 F.2d 355, 359 (7th Cir. 1987), petitioners could not point to any evidence that demonstrated how they planned to reduce their losses. (“The taxpayers’ failure to consult economic experts or develop an economic expertise themselves is another fact that indicates a lack of profit motive”.) Nor could petitioners show how they monitored expenses or losses to enable them to make informed business decisions as to how to make their activity profitable. This factor favors respondent’s position.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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