Dale A. Rinehart and Jeana L. Yeager, f.k.a. Jeana L. Rinehart, et al. - Page 19




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          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 accept              




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