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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 may
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