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anything for sale from their farm. Furthermore, petitioners'
ranch had an unlisted phone number.
Petitioners also failed to show that they intended to change
their operating methods in an effort to increase profitability.
At trial, petitioner made a vague statement about his desire to
expand, reduce his expenses, and leave a profitable business to
his heirs. However, he was unable to articulate any specific
details regarding new techniques that he intended to adapt or
inefficient methods he intended to abandon with respect to his
farm activity. Accordingly, this factor favors respondent.
B. Expertise of Taxpayer or Advisers
The fact that a taxpayer studies the accepted business,
economic, and scientific practices associated with the activity,
or consults with experts, may help demonstrate a profit
objective. Engdahl v. Commissioner, supra at 668; sec.
1.183-2(b)(2), Income Tax Regs.
Petitioner completed the equivalent of 3 years of college.
He did not take any farming or animal husbandry courses in
college; however, from 1988 through the time of trial, he
attended seminars at the University of California at Davis
covering a variety of animal-related issues, such as breeding,
raising, feeding, and medically caring for animals. In addition,
petitioner stayed abreast of developments in the farming and
breeding industry by reading industry books and publications,
such as Track and Trail and National Press Publication. Although
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