- 9 - the economic aspects of breeding cattle; i.e., on how to make the activity profitable, see Burger v. Commissioner, 809 F.2d at 359; (2) read any literature on the business side of breeding cattle; (3) performed any meaningful economic study on the profit potential of breeding cattle; (4) prepared any market analysis on breeding cattle; (5) established a meaningful breeding plan; or (6) studied, or consulted with professionals on, the magnitude of expenses which they were likely to encounter. This factor favors neither party. We consider it neutral. 3. Time and effort spent in conducting the activity We consider the time and effort spent by petitioners in conducting their activity. See sec. 1.183-2(b)(3), Income Tax Regs. The fact that a taxpayer devotes much of his or her personal time to an activity may indicate a profit intent. The failure of a taxpayer to devote substantial time to an activity weighs against a profit objective, unless, for example, the taxpayer employs capable personnel to conduct the activity in his or her stead. Employing capable personnel shows a profit intent. Id. Petitioners have not persuaded us that they spent much time in their breeding activity during the subject years. Although the record contains some testimony establishing that petitioners and their relatives devoted time to the activity during the subject years, we are not persuaded that this aggregate timePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011