- 60 - Our analysis of the nine factors reveals that, overall, Rance did not enter into or continue his cutting horse activity with the requisite profit motive. We hold that respondent’s determination disallowing the losses from that activity was not in error. Zane’s Staffordshire Bull Terrier Activity Zane became interested in dogs when he was 12 years old, after attending a dog show. Thereafter, his parents bought him his first Staffordshire Bull Terrier.7 He became involved in dog showing, breeding, and judging, and by 1985, at age 22, he served as the youngest championship show judge in recent history. During the years in issue he attended many dog shows and owned or coowned as many as 30 to 40 dogs. Most of the dogs lived with their handlers or with his coowners. Zane believed that showing or judging dogs at shows did not normally generate revenue, but breeding and selling puppies could have potential for revenue. More revenue would result if his dogs showed well and/or won medals at a show. Zane has semen stored from two of his dogs. He testified that a breeding typically requires two straws of semen and he could charge around $2,000 per breeding. He estimated that the 80 straws he had at 7 Ultimately, Zane became a noted expert in American and Staffordshire Bull Terriers.Page: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 NextLast modified: March 27, 2008