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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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