Date of decision:
The petitioner, a bankruptcy lawyer whose wife was a college professor, was held to have engaged in his horse activity without a profit intent. As a result, the losses from the activity were largely non-deductible. The court noted that the petitioner had no prior experience in horse activities. While he did spend significant time in the activity, he had no expectation that asset values would increase. There was also no evidence that the petitioner had any past success in related activities. The petitioner incurred a lengthy period of substantial losses and only occasional profits, and there were elements of personal pleasure present. Bronson v. Comr., No. 12-72342, 2015 U.S. App. LEXIS 1745, aff'g., T.C. Memo. 2012-17.