regard, petitioners showed little interest in the charter
activity, the keeping of books for the activity, or the manner in
which the Winterses controlled the boat or conducted the charter
activity.
(2) Expertise of the taxpayer or his advisers.
Mr. Hilliard, although an experienced sailor, had no experience
with chartering a fishing boat. Petitioners had several years of
experience attempting to charter the sailboat. These efforts
resulted in repeated and relatively large losses. Despite these
experiences, petitioners relied on their accountant, Mr. Brazil.
It was not shown that Mr. Brazil had experience with fishing boat
chartering. Petitioners did not seek the expertise of any third
party, and, after the original charter company failed,
petitioners allowed employees of the failed company to continue
in their role as charterer. They allowed the Winterses to
control the boat and arrange charters, even though there were
suspicious circumstances surrounding their former employer. We
find it curious that Mr. Hilliard, when he had made arrangements
with the Winterses, did not inquire about the reason or the
circumstances behind the failure of the original charter company.
(3) Time and effort expended by the taxpayer in carrying on
the activity. Petitioners were engaged in the full-time practice
of medicine. They spent little time with their fishing boat
chartering business. They did not carefully read the analytical
materials provided or investigate the circumstances of the
investment in the fishing boat. Instead, petitioners relied
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