- 8 - reverse the tide, adds further support to our belief that petitioners were, at best, indifferent as to whether the losing trend could be reversed. See Ranciato v. Commissioner, supra at 26. This factor favors respondent's determination. 2. Expertise of taxpayers We consider the expertise of petitioners with respect to their activity. See sec. 1.183-2(b)(2), Income Tax Regs. A taxpayer's expertise, research, and study of an activity, as well as his or her consultation with experts, is indicative of a profit intent with respect thereto. Id. In preparing for an activity, a taxpayer need not make a formal market study, but he or she should undertake a basic investigation of the factors that would affect the activity’s profitability. Underwood v. Commissioner, T.C. Memo. 1989-625; Burger v. Commissioner, T.C. Memo. 1985-523, affd. 809 F.2d 355 (7th Cir. 1987). Mr. Vallette’s prior experiences with cattle made him knowledgeable on the subject. The mere fact that he was skilled in the cattle industry, however, does not mean that petitioners began or continued their breeding activity for profit. Our careful review of this factor suggests that the weight of Mr. Vallette’s expertise and hands-on experience was offset by petitioners’ lack of knowledge on the economics of the cattle breeding industry. Among other things, the record does not suggest that petitioners: (1) Sought any professional advice onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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