Barry D. and Suzanne B. Whalley - Page 40

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          petitioners did not seek advice regarding their farm activity,              
          this fact is not necessarily determinative of a lack of profit              
          motive.  The evidence shows that petitioners made an effort to              
          acquire the knowledge necessary to make their farm activity                 
          profitable, and we find in their favor with respect to this                 
          factor.                                                                     
               C. Time and Effort Expended in the Activity                            
               A taxpayer's devotion of substantial time and effort to an             
          activity, particularly if there are no substantial personal or              
          recreational elements associated with the activity, may indicate            
          the requisite profit objective.  The fact that only a limited               
          amount of time is so devoted does not necessarily give rise to a            
          contrary inference.  Haladay v. Commissioner, T.C. Memo. 1990-45;           
          Archer v. Commissioner, T.C. Memo. 1987-70; sec. 1.183-2(b)(3),             
          Income Tax Regs.                                                            
               In this case, petitioners did not establish that they                  
          devoted a substantial amount of time to their farm activity.                
          Mrs. Whalley is a full-time police officer and student, and                 
          petitioner testified that back problems prevented him from doing            
          a substantial amount of work.  There is evidence that the farm              
          activity was engaged in primarily for personal purposes.  The               
          evidence shows that petitioners deducted substantial costs to               
          train their daughter to ride and participate in equestrian                  
          activities.  For example, petitioners built and deducted the cost           
          of an arena for their daughter's riding practice.  They also                




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