Nora E. Keating and Richard L. Shearer - Page 16




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          scientific and practical aspects of breeding and training and not           
          on the business aspects thereof.                                            
               Petitioner’s discussions with a C.P.A. amounted to little              
          more than how to keep track of and to maintain expense receipts             
          for tax purposes.                                                           
               We conclude that petitioner was not an expert and did not              
          seek out expert advice regarding the economic aspects of carrying           
          on a horse activity for profit.  This factor weighs in favor of             
          respondent.                                                                 

          Time and Effort Petitioner Expended in Carrying On the Activity             
               Section 1.183-2(b)(3), Income Tax Regs., specifies that                
          devotion of much personal time to an activity and withdrawal from           
          another occupation may evidence a profit objective.  This is                
          particularly true where the activity does not have substantial              
          personal or recreational aspects.  Id.                                      
               Petitioner contends that this factor weighs in her favor               
          because she voluntarily opted to work fewer shifts at the                   
          hospital to spend more time on her horse activity.  However,                
          petitioner’s initial reason for working at the hospital only 2              
          and 1/2 days a week was because she felt “burned out” and wanted            
          to spend more time with her children.                                       
               We recognize that feeding and watering horses and cleaning             
          stalls may be unpleasant tasks, but they are involved in caring             
          for horses regardless of whether an activity is pursued as a                






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