Although the taxpayer spent more time on his farming business (which entailed the purchase of mature horses and their training for equestrian jumping and show competitions) than on his land assembly business, his farming losses were restricted given the lack of profitability of the farm (revenues were only a small fraction of expenses), his failure to present any evidence to corroborate his statements concerning his expectations of profit, and his failure to establish that his major preoccupation throughout the taxation years in question was the farm.
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