Nora E. Keating and Richard L. Shearer - Page 15




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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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