Elizabeth Giles - Page 48

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          fisc; i.e., petitioner used her reported losses from the horse              
          activity to reduce significantly her taxable income in every year           
          but one, which in turn reduced her income tax liability for those           
          years.  Contrary to petitioner’s assertion, we do not believe               
          that she engaged in the horse activity to obtain a source of                
          retirement income.  In addition to the fact that she has an IRA,            
          she owns valuable assets in the form of the Gavilan Hills                   
          property, her established dental practice, and the land and                 
          building on and in which her dental practice is located.                    
               This factor favors respondent.                                         
          9.  Elements of Personal Pleasure                                           
               The presence of personal pleasure or recreation from an                
          activity may indicate the absence of a profit objective.  See id.           
          The mere fact that a taxpayer derives personal pleasure from an             
          activity, however, does not necessarily mean that he or she lacks           
          a profit objective with respect thereto.  A profit objective may            
          be present in the latter case if the activity is truly engaged in           
          for profit as evidenced by other factors.  Jackson v.                       
          Commissioner, 59 T.C. 312, 317 (1972).                                      
               Petitioner asserts that the horse activity is neither                  
          recreational nor pleasurable to her because (1) she devotes 30              
          hours per week to the mundane jobs of feeding, maintaining,                 
          grooming, and training her horses and (2) she never rides her               
          horses recreationally.  Petitioner concludes that this factor               






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