Elizabeth Giles - Page 51

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          to indicate that petitioner did not intend that either of those             
          properties be considered part of the horse activity.                        
          11.  Conclusion                                                             
               We conclude that petitioner did not engage in the horse                
          activity during the subject years with a predominant, primary, or           
          principal profit objective.  We reach this conclusion having                
          considered the aforementioned 10 factors, all contentions                   
          presented by the parties, and the unique facts and circumstances            
          of this case.  All arguments made by petitioner but not discussed           
          herein are without merit.                                                   

                                                  Decision will be entered            
                                             for respondent.                          

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