Nora E. Keating and Richard L. Shearer - Page 17




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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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