- 24 -
used in the activity would appreciate in value, and had success
in other breeding activities. Furthermore, Mr. Rinehart
sustained the losses in issue during the startup phase of the
horse breeding activity. Accordingly, we conclude that Mr.
Rinehart engaged in the horse breeding activity during 1994,
1995, and 1996 with the primary purpose and intent of making a
profit within the meaning of section 183.
Our holdings in this opinion will be incorporated into the
decisions to be entered in these cases when all other issues are
resolved.
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Last modified: May 25, 2011