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hobby or as a business. Giles v. Commissioner, T.C. Memo. 2006-
15; see Sullivan v. Commissioner, T.C. Memo. 1998-367, affd.
without opinion 202 F.3d 264 (5th Cir. 1999).
It is evident that petitioner received much satisfaction
from raising and training horses. Since childhood, petitioner
has dreamed of owning horses, and petitioner clearly enjoyed
riding in and entering horse shows. While petitioner may have
spent a significant amount of time with her horse activity,
because the horse activity had significant personal and
recreational components, this factor is neutral.
Expectation of Appreciation in Value
No evidence is before us as to the value of petitioner’s
horses, and it is not possible for us to determine the extent to
which petitioner’s significant losses from her horse activity
someday may be offset by appreciation in value. See Wesinger v.
Commissioner, supra.
This factor weighs in favor of respondent.
Success in Carrying On Other Activity
Petitioner has not engaged in any activity similar to her
horse activity.
This factor is neutral.
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