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personal or recreational aspects. McKeever v. Commissioner,
supra; Daley v. Commissioner, supra. A taxpayer’s withdrawal
from another occupation to devote his or her time and effort to
an activity also may indicate a profit objective. Burleson v.
Commissioner, T.C. Memo. 1983-570; sec. 1.183-2(b)(3), Income Tax
Regs.
Petitioner asserts that she performs almost all of the work
in the horse activity and that she spends 30 hours a week working
in this activity.20 Petitioner concludes that this factor
“clearly” weighs “heavily” in her favor. We disagree.
First, petitioner presented no documentary evidence to
support her claim that she spent 30 hours per week working on the
horse activity, and we find that the referenced 30 hours includes
all of the time that petitioner spent with her horses, including
time that was personal or recreational to her. We thus discount
her testimony that 100 percent of the time that she spent with
her horses was for business. We also note that this testimony is
somewhat incredible on its face. Petitioner was deeply involved
with horses before starting the horse activity in 1988, and she
bought her first horse because she missed the pleasure of being
with horses. It is quite a stretch for her now to ask us to
believe that her only involvement with horses since 1988 has been
20 Although petitioner testified generally that she budgeted
“at least” 30 hours a week to spend with her horses, she argues
in her brief that she spent a flat 30 hours.
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