An individual who bought shares in racehorses and in horseracing partnerships was not trading commercially with a view to profit and was therefore not entitled to relief against general income for the losses incurred. 
 
In the tax years 2007/08 to 2012/13 inclusive, the appellant was a self-employed tax consultant, offering his services to racehorse trainers, jockeys, breeders and others in the equine industry. In addition, during those tax years the appellant considered himself to be self-employed as a ‘dealer in thoroughbreds’. This was the term used by the appellant to describe his purchase of shares in racehorses and in horseracing partnerships. 
 
The appellant considered that he had sufficient expertise and experience to turn this activity into a commercial venture from 1 January 2008. He informed HM Revenue and Customs (HMRC) that he ceased treating his activity as a commercial venture