- 24 - his mind and his time after his retirement as an insurance agent. Thus, we think Red Caboose allowed Mr. Lencke to pursue, upon his retirement, his interest in and the pleasures of collecting model railroad equipment and memorabilia. Although its operation extended petitioners' interest in model railroading into a more formal pursuit, it does not necessarily follow that they were primarily motivated by an intention to make Red Caboose a profitable venture. While it is not required that a taxpayer dislike an activity before it will be considered a business and not a hobby, Jackson v. Commissioner, 59 T.C. 312, 317 (1972), petitioners have not shown a profit objective with respect to their model railroad activity. Consequently, their interest in operating Red Caboose has strong recreational and personal elements. In reaching our conclusion that Red Caboose's operation was not an activity engaged in by petitioners for profit, we have considered that, before starting Red Caboose, they planned and coordinated the activities to be pursued through Red Caboose, visited model railroad shows, and sought advice from various vendors of model railroad supplies, and that they promoted Red Caboose by advertising in model railroad and toy magazines, publishing and distributing a two-page flyer listing Red Caboose's merchandise, creating business cards, and allowing visitors to tour the model railroad collection displayed in the basement of their home. We have also considered that petitionersPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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