Michael Paul Remler and Pauline M. Velez - Page 11

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          businesslike manner.  These facts weigh in favor of respondent.             
               2.   Expertise of Petitioners or Their Advisers                        
               Preparation for the activity by extensive study of its                 
          accepted business, economic, and scientific practices, or                   
          consultation with those who are expert therein, may indicate a              
          profit motive.  Sec. 1.183-2(b)(2), Income Tax Regs.; Engdahl v.            
          Commissioner, supra at 668; Lundquist v. Commissioner, T.C. Memo.           
          1999-83, affd. 211 F.3d 600 (11th Cir. 2000).  Efforts to gain              
          experience and a willingness to follow expert advice may indicate           
          a profit motive.  Dworshak v. Commissioner, T.C. Memo. 2004-249;            
          Lundquist v. Commissioner, supra.                                           
               Dr. Remler served as the child neurologist for TEACCH at the           
          University of North Carolina.  Petitioners also received guidance           
          and training in special education methods from BIA and AIA.                 
          While petitioners had no experience running a school, we find               
          that Dr. Remler had expertise in dealing with child autism, and             
          petitioners made efforts to gain experience in special education.           
          These facts weigh in favor of petitioners.                                  
               3.   Time and Effort Expended by Petitioners in Carrying               
                    on the Activity                                                   
               The fact that the taxpayer devotes much of his personal time           
          and effort to carrying on an activity may indicate an intention             
          to derive a profit, particularly if the activity does not have              
          substantial personal or recreational aspects.  Sec. 1.183-                  






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