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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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