General K. Hilliard and Ida M. Hilliard - Page 18

               Petitioners failed to conduct any meaningful investigations            
          of the fishing boat venture, and they relied on their accountant.           
          That reliance is not reasonable under circumstances where the               
          accountant has not been shown to have had any expertise.                    
          Petitioners had loss experiences with the chartering of their               
          sailboat, and they did not attempt to determine if the same                 
          problems could occur with chartering the fishing boat.  Their               
          lack of action and lack of interest regarding the operation of              
          the fishing boat charter reflect that their motivation was                  
          primarily tax benefits.  Further inquiry might have given                   
          petitioners insight into the likelihood of many of the problems             
          that they encountered.  See Thomas v. Commissioner, 84 T.C. 1244,           
          1278 (1985), affd. 792 F.2d 1256 (4th Cir. 1986).                           
               Based on the entire record, we are not convinced that                  
          petitioners' primary objective was to make a profit.  See Snyder            
          v. United States, 674 F.2d 1359, 1362-1364 (10th Cir. 1982).                
          Petitioners did not have an actual and honest objective of making           
          an economic profit independent of tax savings.  We hold that                
          petitioners' fishing boat chartering activity was not engaged in            
          for profit within the meaning of section 183(c).                            

          IV.  Tahoe Rental Activity6                                                 
               Petitioners acquired a residence in Tahoe by paying $11,000            
          in mortgage payment arrears and by accepting responsibility for             


               6 If we find that petitioners' residential rental activity             
          was engaged in for profit, then petitioners concede that the loss           
          limitation rules under sec. 280A(e) apply.                                  



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