James J. Hogan - Page 11




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          his profitability.  To begin with, petitioner stated that his               
          location “was one mile off Route 417 on a side road called                  
          Sullivan Hollow, which pretty much meant that I wasn’t going to             
          get drive by business.”  Petitioner testified that he “cut back             
          quite a bit on advertising” and reduced the price charged for the           
          rooms.  Petitioner’s ads were attractive but did not display his            
          building, apparently because his bed and breakfast building would           
          not compare favorably with other bed and breakfast buildings                
          which were pictured in the other ads he offered into evidence.              
          We note that none of the changes made by petitioner, in essence             
          to reduce losses and control costs, had any material effect.                
          Petitioner continued to incur sizeable losses.  Thus, we find               
          petitioner did not carry on the activity in a businesslike                  
          manner.  We conclude that this factor is not indicative of the              
          requisite profit objective.                                                 
               We consider the expertise of the taxpayer.  A taxpayer’s               
          expertise, research, and study of an activity, as well as his               
          consultation with experts, may be indicative of a profit                    
          objective.  Sec. 1.183-2(b)(2), Income Tax Regs.  Prior to                  
          operating the Camelot Inn, petitioner served as a chef in the               
          United States Army.  Ms. Hughes worked during college as a                  
          housekeeper and receptionist at a motel.  Petitioner belonged to            
          the Cattaraugus County Tourism Bureau and the National Bed and              
          Breakfast Association.  However, petitioner testified that he had           
          no prior experience operating a bed and breakfast.  Prior to                
          starting the bed and breakfast, petitioner did not consult                  





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