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.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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