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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 petitioners
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