- 20 - the valuation proposed by Mr. Rodriguez; petitioner argues that we should accept the valuation proposed by Mr. Bierschwale. Both reports, however, conclude that by the close of the last taxable year in issue (1996) the Campbell ranch increased in value from its purchase price. The only dispute between the parties is to whether value increased by $56,000 or $150,000. The Campbell ranch increased in value by at least $56,000, and this supports Mr. Rinehart’s expectation that the assets used in the activity would appreciate in value and petitioners’ contention that the horse breeding activity was engaged in for profit.22 Additionally, IRS economist Roderick Moss testified that he thought Mr. Rinehart’s horse breeding activity could be profitable in the future. Accordingly, we conclude that this factor favors petitioners for the years in issue. Mr. Rinehart’s Success in Similar or Dissimilar Activities The uncontradicted evidence establishes that Mr. Rinehart enjoyed success in two previous cattle activities--the polled Hereford breeding activity and the Hereford breeding activity. This is indicative of the requisite profit motive. History of Income or Loss Mr. Rinehart incurred hundreds of thousands of dollars in 22 We note that the parties submitted evidence regarding the valuation of petitioners’ herd of horses. The factual and expert evidence, however, concerns the value of the horses in 2000--a year well beyond the years in issue.Page: 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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