Geraldine H. Pearson - Page 12

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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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