- 49 -
overwhelmingly weighs in her favor. We disagree.27 First, as
noted above, we find from a factual point of view that petitioner
rides her horses recreationally and that the 30 hours per week
that she spends with her horses includes this recreational time.
Thus, even if we were to agree with petitioner that her
referenced jobs were all “mundane”, we would not agree that all
of her time was spent performing these jobs. See also Dodge v.
Commissioner, T.C. Memo. 1998-89 (substantial time that the
taxpayers spent in their horse breeding activity did not indicate
a profit objective because the taxpayers, who were skilled
riders, derived recreational benefit from the time they spent
with their horses); Ballich v. Commissioner, T.C. Memo. 1978-497
(substantial time that the taxpayers spent on breeding and
showing their dogs indicated that the activity was a “labor of
love” rather than an undertaking to derive profit).
Second, contrary to petitioner’s claim, the record shows
that during the subject years she did not perform all of the work
in the horse activity. Petitioner deducted for those respective
years expenses of (1) $1,330 and $714 for outside services,
(2) $1,518 and $1,645 for training, (3) $1,382 and $1,453 for
27 We note at the start that we disagree with petitioner’s
statements in brief that a finding of personal pleasure requires
that we find evidence of parties at the Falling Water Way
property or social activities involving her horses.
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