Elizabeth Giles - Page 45

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          fact, conducted for profit as evidenced by other factors.                   
          Sec. 1.183-2(b)(9), Income Tax Regs.                                        
               Despite petitioner’s testimony that her horse activity                 
          did not have any personal or recreational aspects,                          
          petitioner certainly derives some personal pleasure from                    
          riding and showing her horses, as discussed above.  However,                
          this does not, by itself, indicate that petitioner lacked a                 
          profit motive.  Accordingly, this factor is neutral.                        
               Conclusion                                                             
               Petitioner repeatedly testified that she intended to                   
          derive a profit from her horse activity and wished to use                   
          the activity as her source for retirement income.                           
          Petitioner’s assertions, however, are not supported by the                  
          facts.  In 16 years of operation, petitioner had 1                          
          profitable year.  Despite continual heavy losses, petitioner                
          did not seek out expert advice, or attempt to educate                       
          herself, on the economic aspects of running a profitable                    
          horse-breeding business.  Petitioner did not operate the                    
          activity in a businesslike manner.  In addition, if not for                 
          her significant annual wage and rental income, petitioner                   
          would have been unable to continue the horse activity at a                  
          loss year after year.  The only factor weighing in favor of                 
          petitioner, the appreciation of Falling Water Way and                       







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