I wouldn’t spend much time on Raymond Price, III and Lynn M. Price, 2014 T. C. Memo. 253, filed 12/16/14. It’s another one of those heavy-hitter looking to have the taxpayers pay for his/her horse hobby, fact-intensive cases. But RP3’s inventive counsel sets up Judge Nega for an entry in the Tax Court Line of the Year competition.

RP3 is a horse-loving son of a US Olympian (equine variety) who makes a fortune in the family car business. He builds himself a country retreat with much horsing (breeding, riding, buying and selling), but IRS establishes that his twenty-year string of losses and eve-of-trial paperwork demolish any profit motive. And cars and horses don’t mix; at least, not enough to be treated as one enterprise.

But RP3’s counsel come up with what has to be the Taishoff “Good Try” Third Class of the year. “Petitioners contend that there are some aspects of each activity that are conducted at the same locations. For example, petitioners cite the receipt of cooled stallion semen at the Honda dealership as evidence that a horse activity is conducted at that dealership.” 2014 T. C. Memo. 253, at p. 34.

Judge Nega is not impressed. “These arguments are unconvincing. Just as mailing a personal letter from one’s place of business does not transmute the nature of the letter, the receipt of cooled stallion semen at the Honda dealership does not make the automobile dealership a location where horse sales are conducted.” 2014 T. C. Memo. 253, at p. 34.

Ya can’t make this stuff up.