- 27 - 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 asPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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