- 19 - of the horse breeding business including showing, breeding, and selling the horses. Over the years, he hired professionals to train his horses. When Doc Bar was not producing foals, Mr. Rinehart sought advice from veterinary experts and had the stallion evaluated by experts. In 1996, Mr. Rinehart added the services of a specialist in equine reproduction, Dr. Allen, to the horse breeding activity. We conclude that this factor is indicative of the requisite profit motive. Time and Effort Expended by Mr. Rinehart Mr. Rinehart was engaged in all aspects of the horse breeding activity including: (1) Hiring and firing all labor, (2) purchasing of mares and stallions, (3) breeding and raising the horses, (4) training of the horses, (5) culling the horses, (6) maintaining the horses, (7) advertising the activity, and (8) promoting the activity. Respondent concedes that Mr. Rinehart spent significant amounts of time in carrying on the horse breeding activity. This factor is indicative of the requisite profit motive. The Expectation That Assets May Appreciate in Value A number of experts testified at trial. Internal Revenue Service (IRS) real estate appraiser Armando Rodriguez concluded that as of December 31, 1996, the value of the Compass R Ranch was $406,000. Paul Bierschwale, a real estate appraiser, concluded that as of December 31, 1996, the value of the Compass R Ranch was $500,000. Respondent argues that we should acceptPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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