- 12 - 10 hours per day during weekends, vacations, and other days that she had no outside work. In contrast, petitioner devoted relatively little time and effort to her farm from July 1, 1988, to May 31, 1989, when she was in Virginia. Petitioner contends that her moving to Virginia does not show that she lacked a profit objective because she arranged for friends to manage her farm. She testified that she contacted "persons responsible for the various farm operations and livestock in her absence" by telephone at least twice a week while in Virginia. Stockfleth visited petitioner's farm twice a week. During lambing season, Stockfleth or her daughter visited petitioner's farm every day. We cannot reconcile the small amount of time Stockfleth (or anyone else) spent at the farm during petitioner's absence with the substantial amount of time petitioner estimated she spent working on the farm. If petitioner spent the time working on the farm stated above, then it appears that the arrangement with Stockfleth and petitioner's neighbors was inadequate. Conversely, if Stockfleth's occasional visits and the availability of others to help in emergencies were sufficient to run the farm, petitioner has not adequately explained why she had to devote as much time to the farm as she did. This factor favors petitioner somewhat. 4. Taxpayer's Success in Other Activities The fact that a taxpayer has previously engaged in similar activities and converted them from unprofitable to profitable mayPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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