Tolbert S. Wilkinson and Suzanne T. Wilkinson - Page 14

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          to increase profitability.  See De Mendoza v. Commissioner, T.C.            
          Memo. 1994-314.  This factor favors respondent.                             
               2.  Expertise of Petitioner or His Advisers                            
               Preparing to enter into an activity by consulting with                 
          experts or extensive study may indicate that a taxpayer has a               
          profit objective.  Sec. 1.183-2(b)(2), Income Tax Regs.                     
               Petitioner has no formal schooling in agriculture or                   
          equestrian activities.  His participation in equestrian                     
          activities began during the 1970's, while his participation in              
          polo began around 1984.  Petitioner was very involved in the polo           
          community, and was even a contributing editor for Polo magazine.            
          Although we believe he was quite knowledgeable as to polo, or               
          even equestrian affairs, we do not feel that he was an expert in            
          making equestrian affairs profitable, and it does not appear that           
          he had any experience or expertise in the cattle, other animals,            
          hay, or guest quarters business.  Petitioners have failed to                
          establish that they sought expert advice to make the ranch                  
          profitable.  This factor favors respondent.                                 
               3.  The Time and Effort Expended by Petitioner                         
               A devotion of a great deal of a taxpayer's personal time to            
          an activity, especially where there is no recreational element,             
          may indicate a profit objective, and the fact that only a limited           
          amount of time is so devoted does not necessarily give rise to a            
          contrary indication.  Sec. 1.183-2(b)(3), Income Tax Regs.                  






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