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taxpayers carry on the activity; (2) the expertise of the
taxpayers or their advisers; (3) the time and effort expended by
the taxpayers in carrying on the activity; (4) the expectation
that the assets used in the activity may appreciate in value; (5)
the success of the taxpayers in carrying on similar or dissimilar
activities; (6) the taxpayers’ history of income or loss with
respect to the activity; (7) the amount of occasional profits;
(8) the financial status of the taxpayers; and (9) whether
elements of pleasure or recreation are involved. Golanty v.
Commissioner, supra at 426; sec. 1.183-2(b), Income Tax Regs.
Based on our consideration of these factors and in the light
of the detailed record in this case, we conclude that
petitioners’ horse-boarding activity was carried on as a business
within the meaning of sections 162 and 183 during the taxable
years at issue. In reaching this conclusion, we view the
following facts and circumstances as most persuasive:
Manner in Which Taxpayers Carried On the Activity
Respondent contends that the manner in which petitioners
conducted their horse-boarding activity does not indicate that
the activity was engaged in for profit during the years in issue.
The relevant inquiries before us include whether petitioners
conducted their business in a manner similar to other comparable
businesses, whether petitioners maintained complete and accurate
books and records, and whether changes were attempted to improve
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