- 40 - 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 alsoPage: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
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