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a sign in the window for people to call them if they wanted to
see something in the store. This factor favors respondent.
2. The Expertise of the Taxpayers or Their Advisors
Preparation for an activity by extensive study of its
accepted business, economic, and scientific practices, and
consultation with experts in the business, may indicate that the
taxpayer entered into the activity for profit. Sec. 1.183-
2(b)(2), Income Tax Regs. Petitioners had no experience
operating a retail store. Petitioners spoke to a couple of
people about operating an antique store, but, the record contains
little detail about the substance of those conversations, and
there is no evidence that petitioners sought any advice about how
to correct the store's losses in the years in issue. See Engdahl
v. Commissioner, supra at 668 (continuous consultation with
experts showed profit motive). This factor favors respondent.
3. Taxpayer's Time and Effort
The fact that a taxpayer devotes much time and effort to
conducting an activity may indicate that the taxpayer has a
profit objective. Sec. 1.183-2(b)(3), Income Tax Regs. There is
virtually no evidence about how Mrs. Brockenbrough spent her time
at the store. Petitioners did not operate the store on a full-
time basis after 1990. This factor favors respondent.
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