Jane Freed - Page 12

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          thoroughbred horse activities for 14 years and has many other               
          clients who raise horses as well.                                           
               We place little weight on respondent’s argument that                   
          petitioner lacks the requisite expertise because neither she nor            
          her advisers are experts in the economics of thoroughbred horses.           
          Petitioner does not need advanced training in economics to know             
          that a thoroughbred horse that wins races is more valuable than             
          one that does not.  Petitioner’s advisers have demonstrated an              
          expertise in breeding and training winning thoroughbreds, and she           
          has demonstrated a willingness to solicit and follow their                  
          advice.                                                                     
               3.  The Time and Effort Expended by the Taxpayer in                    
               Carrying On the Activity                                               
               We next consider the time and effort petitioner expended in            
          carrying on her thoroughbred horse breeding and racing                      
          activities.  A taxpayer’s devotion of much time and effort to               
          conducting an activity, particularly if the activity does not               
          involve recreational aspects, may indicate that he or she has a             
          profit objective.  Sec. 1.183-2(b)(3), Income Tax Regs.                     
               Petitioner claims to have spent 10 to 20 hours per week on             
          bookkeeping alone.  In addition, she claims that she spent time             
          reading industry-related publications as well as time talking to            
          her breeding and training managers.  Respondent counters that               
          petitioner overstated the amount of time and points out that,               







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