J. Michael and Susan Reimer - Page 28




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          satisfaction from his work; however, where the possibility for              
          profit is small (given all the other factors) and the possibility           
          for gratification is substantial, it is clear that the latter               
          possibility constitutes the primary motivation for the activity.”           
          Burger v. Commissioner, supra.                                              
               Because petitioners derived substantial personal pleasure              
          from their horse breeding activity, including showing their                 
          horses, this factor favors respondent.                                      
          L.   Conclusion                                                             
               Considering all the facts and circumstances, we find that              
          petitioners’ horse breeding activity was not engaged in for                 
          profit within the meaning of section 183(c).  In reaching our               
          decision, we have considered the factors listed in section 1.183-           
          2(b), Income Tax Regs., all arguments presented by the parties,             
          and the unique facts of this case.                                          
               Petitioners engaged in their horse breeding activity for at            
          least 22 years, with a net loss of at least $217,356 during 1992            
          through 1998.  Petitioners did not generate a profit or even come           
          close to doing so during any of the years in issue.  We do not              
          question petitioners’ dedication to their horses.  But, based               
          upon the totality of the circumstances and the objective facts,             
          petitioners’ arguments are unsupportable that their horse                   
          activity was engaged in for profit.  Petitioners did not prepare            
          for the economic realities of the horse breeding business as                







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