did not seek out the assistance of their accountant or any other
assistance in connection with their sailboat charter activity.
(3) Time and effort expended by the taxpayer in carrying on
the activity. Petitioners, both of whom were full-time medical
doctors, spent little time with the chartering business. The
extent of their efforts included merely placing the sailboat in a
marina and attempting to solicit charter activity by placing
notices on bulletin boards at the hospitals where they worked.
(4) Expectation that assets used in the activity may
appreciate in value. Mr. Hilliard expected to benefit from
gaining equity in the boat by making monthly mortgage payments
derived from boat charter revenues. Mr. Hilliard was aware that
his sailboat was not likely to appreciate in value. Although,
for several years, the sailboat generated relatively large
amounts of expenses and little or no income, petitioners did not
make any meaningful changes to their approach, other than to move
the boat to another marina. Petitioners were content to claim
the deductions and have the boat available for their use during
the summer boating season.
(5) The success of the taxpayer in carrying on other similar
or dissimilar activities. Petitioners' attempt to charter the
sailboat was their first attempt at chartering. They offered no
other evidence of their success in other types of chartering
businesses prior to that date.
(6) The taxpayer's history of income and loss with respect
to the activity, and (7) the amount of occasional profits, if
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