A married couple operated numerous Steak 'n Shake franchises, but later also began breeding and training Tennessee Walking Horses. After the husband died in a 2003 house fire, the surviving spouse became President of the corporation that ran the franchises and was very involved in the franchise businesses. The couple had purchased several hundred acres in TN for slightly under $1 million to operate their horse breeding and training activity. They ran up substantial losses from the horse activity which they attempted to deduct. The IRS denied the deductions and the surviving spouse paid the tax and sued for a refund. The court upheld the IRS determination. The court noted that under the multi-factor analysis the taxpayers (and later the widow) didn't substantially alter their methods or adopt new procedures to minimize losses, didn't get the advice of experts and continued to operated the activity while incurring the losses. The court noted that the losses existed long after the expected start-up phase would have expired. Profits were minimal in comparison and the taxpayers had substantial income from the franchises. Also, the court noted that the widow had success in other ventures, those ventures were unrelated to horse activities. Estate of Stuller v. United States, No. 11-3080, 2014 U.S. Dist. LEXIS 100617 (C.D. Ill. Jul. 24, 2014).