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gambling activity. Although petitioner maintained only a single
bank account, his gambling winnings and losses were accounted for
separately. Accordingly, this factor favors petitioner.
A profit objective might be indicated where the taxpayer
carries on an activity in accordance with practices learned from
extensive study of accepted business and economic practices, or
consultation with experts involved therein. Sec. 1.183-2(b)(3),
Income Tax Regs. Petitioner has been gambling on horseraces for
more than 25 years. Petitioner has been “seriously” handicapping
horseraces for 11 years. This includes preparing detailed “speed
figures” for the winner of each race. Petitioner sought advice
from, as well as provided advice to, other individuals who
gambled on a regular basis. Finally, through the years
petitioner has read numerous books published on gambling and
handicapping horseraces. This factor favors petitioner.
A profit objective might be indicated where the taxpayer
uses much of his personal time and effort to carry on the
activity. Sec. 1.183-2(b)(4), Income Tax Regs. Petitioner
spends about 40 hours pursuing his gambling activity. During
2001, he spent approximately 250 days gambling and handicapping
horseraces. Petitioner’s detailed records, including the self-
prepared “speed figures”, are evidence of the time and effort
expended by petitioner away from the race track. We are
convinced that petitioner spent a significant amount of time
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