- 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 NextLast modified: May 25, 2011