In this case, the petitioner was a lawyer in Minnesota that had a client that introduced him to horse racing. He got heavily involved in horse breeding activities in Louisiana. The petitioner sustained losses associated with his horse activities and IRS limited deductibility under the passive loss rules of I.R.C. Sec. 469, conceding that petitioner was engaged in the horse activities with a profit intent. Court determined that petitioner satisfied material participation test of I.R.C. Sec. 469 based on telephone logs, credit card invoices, and other contemporaneous materials including trips to Louisiana, buying insurance, recordkeeping and continuing education. Court did not require petitioner to call customers as witnesses. Tolin v. Comr., T.C. Memo. 2014-65.