- 13 -
Commissioner, supra at 430; Giles v. Commissioner, T.C. Memo.
2006-15; Burger v. Commissioner, supra.
Petitioner contends that her methods of advertising were
similar to other horse-breeding operations and evidence her
profit objective. While we recognize that participation in horse
shows provides some advertising, see Engdahl v. Commissioner, 72
T.C. 659, 662-663 (1979), we find in this case that petitioner’s
advertising efforts were minimal. Where we have found that an
animal breeder operated in a businesslike manner, generally the
breeder not only participated in shows but engaged in other forms
of substantial advertising. See Engdahl v. Commissioner, supra
at 667 (advertised in horse publications); Rinehart v.
Commissioner, T.C. Memo. 2002-9 (advertised in horse publications
and gave out promotional materials); Routon v. Commissioner, T.C.
Memo. 2002-7 (advertised in trade publications and mailed
promotional videos); Strickland v. Commissioner, T.C. Memo. 2000-
309 (advertised in local newspaper); Davis v. Commissioner, T.C.
Memo. 2000-101 (advertised in newspapers and distributed
promotional clothing); Phillips v. Commissioner, T.C. Memo. 1997-
128 (distributed promotional videos and participated in horse
associations for the purpose of advertising); Burrow v.
Commissioner, T.C. Memo. 1990-621 (prepared promotional videos
and advertised in horse publications). As we have found,
petitioner’s advertising and promotion of her horse activity were
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