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party's position. Taube v. Commissioner, supra at 480; Dunn v.
Commissioner, supra at 720.
The Manner in Which the Taxpayer Carries On the Activity.
Generally, the fact that a taxpayer carries on an activity in a
businesslike manner and maintains complete and accurate books and
records may indicate that the activity is engaged in for profit.
Sec. 1.183-2(b)(1), Income Tax Regs.
Petitioners advertised in various boating magazines and
journals. They attended two boat shows in Seattle, Washington,
and Alameda, California, respectively, in 1988. Petitioners,
however, had no written business plan and did not take reasonable
steps to implement their stated objectives. Petitioners'
principal contention is that they could not carry on their yacht-
related activities because they lacked a demonstration boat to
represent Kanter Yachts and display or sell boating equipment.
We are not convinced that the lack of either Brendan or Trinity
formed an insuperable barrier to selling boating equipment or
yachts.
Petitioners failed to conduct even a basic investigation of
the profitability of selling yachts and boating equipment before
entering into the activity. Their business plan assumed that
they would earn income through the sales of yachts and boating
equipment. Petitioners' primary method of selling Kanter Yachts
was through boat shows. Petitioner husband testified that he was
hoping to eventually sell three yachts per year. However,
despite the fact that Brendan was demonstrated in both the
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