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because petitioner lived in another State, she could not have
devoted as much time to these activities as she claims.
We find that petitioner failed to corroborate her testimony.
We are not required to accept petitioner’s uncorroborated, self-
serving testimony. See, e.g., Niedringhaus v. Commissioner, 99
T.C. 202, 219-220 (1992); Tokarski v. Commissioner, 87 T.C. 74,
77 (1986).
Petitioner then analogizes this case to numerous other
thoroughbred horse cases where the taxpayers dedicated comparable
amounts of time to their activities. See, e.g., Smith v.
Commissioner, 9 T.C. 1150 (1947); Eisenman v. Commissioner, T.C.
Memo. 1988-467; Appley v. Commissioner, T.C. Memo. 1979-433. We
decline to detail the distinctions between this case and each of
these other cases. The potentially infinite combination of
factors that affect this analysis makes it virtually impossible
to analogize the importance of any one factor in relation to the
others under different scenarios.
4. The Expectation That the Assets Used in the
Activity May Appreciate in Value
We next examine the expectation that the assets used in
petitioner’s thoroughbred horse breeding and racing activities
may appreciate in value. A taxpayer may intend, despite the lack
of profit from current operations, that an overall profit will
result when appreciation in the value of assets used in the
activity is realized. Bessenyey v. Commissioner, 45 T.C. 261,
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