- 32 - in the ponds to help fish survive, and placed property in Government subsidy programs. Petitioners also abandoned their efforts to raise a crop on their land altogether after they realized it would be unprofitable to do so. (2) Expertise of the Taxpayer or His Advisers Section 1.183-2(b)(2), Income Tax Regs., provides in pertinent part as follows: Preparation for the activity by extensive study of its accepted business, economic, and scien- tific practices, or consultation with those who are experienced therein, may indicate that the taxpayer has a profit motive where the taxpayer carries on the activity in accordance with such practices. * * * Although Mrs. Holmes lived on a farm as a child and petitioner occasionally worked on his father's farm, neither of them had any professional experience in farming. However, petitioner did consult with neighboring farmers, the local ASC office, and his accountant prior to commencing his farming activities. Petitioner also had some limited experience in growing, harvesting and selling Christmas trees and timber. Finally, petitioner testified that he attended at least one seminar at the Michigan State Biological Station on raising fish and regularly read local trade magazines.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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