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horses that will give * * * [petitioner] a good reputation,
horses that will do well in the market” is inadequate for us to
conclude that petitioner had an established business plan. See
Wesinger v. Commissioner, T.C. Memo. 1999-372; Sanders v.
Commissioner, T.C. Memo. 1999-208 (finding similar testimony
inadequate).
The fact that petitioner hired a professional trainer to
finish training her horses is not particularly helpful to
petitioner. A hobby breeder who enters horses in shows to
enhance her reputation and to participate in competition also may
hire a professional trainer to finish training the horses.
We conclude that petitioner did not operate her horse
activity in a businesslike manner. This factor weighs in favor
of respondent.
Expertise of Petitioner and Her Advisers
In considering this factor the focus is upon expertise and
preparation with regard to the economic aspects of a particular
business. See, e.g., Golanty v. Commissioner, 72 T.C. at 432.
While petitioner may have developed an expertise in the
breeding and training of horses, her expertise did not extend to
the economics thereof. Petitioner testified that she consulted
with a successful breeder, several professional trainers, and a
veterinarian, but the discussions focused primarily on the
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