- 11 - activity, and did not maintain an inventory accounting for each of his horses. His testimony indicates that petitioner’s primary expectation for a profit comes from the anticipated appreciation in the value of his assets, his ranch property and improvements and his horses. Because of the absence of supporting documentation, such as an outside appraisal, records from the sale of comparable ranch property in the area, or receipts for the cost of the improvements to his ranch, petitioner failed to substantiate the value of his ranch. Furthermore, in response to direct questioning from this Court, petitioner admitted that the current value of his ranch is probably less than the cumulative amount of losses he has claimed from his horse activity. Petitioner speculated that his property will continue to appreciate tremendously in the future, but he did not introduce any objective evidence of projected increases in property values in the area of his ranch for the Court to consider. As to the values of his horses, petitioner’s 1997 return showed a sale of a horse at a loss of $7,500, undermining his own unverified and self-serving testimony that he expects to profit from the sale of his horses. Petitioner failed to substantiate the value of his assets or the likelihood of any appreciation in the value of these assets. The record clearly shows that petitioner’s horse activity has produced a history of losses. For each year sincePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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