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financial aspects of their respective horse breeding activities.
However, petitioner did not elaborate on those conversations
regarding the advice, if any, or on the economic aspects of horse
training and breeding. Petitioner and his wife may have received
some advice on the economic aspects of horse breeding, but the
facts do not indicate that petitioner received any specific
business advice on how to start and operate a horse breeding
business.
Petitioner’s wife has handled, ridden, and cared for horses
all of her life. Apparently, Mrs. Ryan had gained substantial
experience in the training, breeding, health, and maintenance of
horses since leaving high school. Mrs. Ryan’s experience is not
the same as knowledge of the financial aspects of creating a
profitable horse breeding program. See McKeever v. Commissioner,
T.C. Memo. 2000-288 (taxpayer’s background as a lifelong
horsewoman did not provide sufficient expertise on the economic
aspects of a horse pursuit to indicate a profit objective). This
factor weighs against petitioner.
3. The Time and Effort Expended by the Taxpayer in
Carrying On the Activity
The fact that a taxpayer devotes much of his or her personal
time and effort to an activity may indicate a profit objective,
especially where the activity does not involve substantial
personal or recreational aspects. Id.
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