S.K. Johnston, III and Julie N. Boyle f.k.a. Julie N. Johnston, et al. - Page 18

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            that the Johnstons could easily afford to operate the farm                                
            activity at a loss.  This fact alone, however, is not overly                              
            persuasive, because "As long as tax rates are less than 100                               
            percent, there is no 'benefit' in losing money."  Engdahl v.                              
            Commissioner, 72 T.C. at 670.                                                             
                  Finally, the following factors are indicative of a profit                           
            motive.  The parties stipulated that petitioners conducted their                          
            farm activity in a businesslike manner, maintained accurate books                         
            and records, hired expert advisers, employed competent farmhands,                         
            and had personal experience in the activity in question.  The                             
            parties further stipulated that Gillian Johnston regularly                                
            performed hard manual and menial labor at Bendabout, including                            
            feeding and grooming horses, mucking out stalls, and cleaning                             
            barns.                                                                                    
                  Respondent further concedes that petitioners responded to                           
            setbacks at the farm and tried to make corrective changes in its                          
            overall operations, including changing management two or three                            
            times and trying to increase the value of Bendabout's brood mares                         
            by breeding them to good pedigreed stallions in New York and                              
            Kentucky, such as D'Accord and Java Gold, both of which had good                          
            stud records.                                                                             
                  Moreover, a taxpayer's regular experimentation with new                             
            sources of revenue is further evidence of a profit motive.  Hoyle                         
            v. Commissioner, T.C. Memo. 1994-592.  Here, petitioners                                  
            continued to seek out the most profitable uses for the farm,                              



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