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Elements of Pleasure/Recreation
Respondent argues that not only are Mr. Rozzano’s claims
regarding his involvement with the work done at Sugar Tree
improbable, but that regardless of the amount of effort
petitioners put into the activity, elements of pleasure should
trump any consideration that the activity was a business. We
disagree. Until sometime in 2000, petitioners resided at least 5
hours away from Sugar Tree. This distance required petitioners
to travel between their home and Sugar Tree on weekends and
holidays. We believe, based on their credible testimony at
trial, that once at Sugar Tree, petitioners did perform a
significant amount, if not all, of the major upkeep on the
property. Furthermore, petitioners did not ride either of their
horses for pleasure after 1990. We do not find that the
pleasure that petitioners may have experienced through their
ownership of Sugar Tree should trump a finding that the horse-
boarding activity was operated for profit. See Jackson v.
Commissioner, 59 T.C. 312, 317 (1972).
Possibly the only elements of pleasure taken by petitioners
were either when watching their own horses frolic in the pasture
or in the mere fact that they could attest to “owning a horse
farm near Lexington, Kentucky.”
Therefore, on the basis of all of the evidence in the record
of this case, the circumstances of which are unique, we conclude
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