- 13 - ability to earn this income let them finance their breeding activity, and it allowed them to use the activity's losses to reduce significantly their income tax liability for each year. This factor favors respondent's determination. 9. Elements of personal pleasure We consider the personal pleasure derived by petitioners from conducting their activity. See sec. 1.183-2(b)(9), Income Tax Regs. Although the mere fact that a taxpayer derives personal pleasure from a particular activity does not negate a profit intent with respect thereto, the presence of personal motives may indicate that the activity is not engaged in for profit. This is especially true where there are recreational or other personal elements involved. Id. Our review of the record, in conjunction with our observation of petitioners during their testimony, leads us to believe that they had strong personal reasons for breeding cattle. Our observation of petitioners testifying at trial leads to the inescapable conclusion that they each gained significant personal pleasure from their involvement in the cattle industry, and that their enjoyment and satisfaction would have been the same regardless of the activity’s bottom line. See Ballich v. Commissioner, T.C. Memo. 1978-497. Among other things, we believe that Mr. Vallette, the backbone of petitioners' breeding activity, engaged in that activity due to his affection for cattle. He has been involved with cattle since a very young age,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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