- 25 - their losses by changing their approach. Hence, Pryor v. Commissioner, supra, is distinguishable. Petitioners also rely on Dickson v. Commissioner, T.C. Memo. 1983-723, in which we found that despite losses, due to economic conditions, the taxpayer was engaged in the business of chartering his boat with a profit motive. We also found that the taxpayer actually and honestly expected his boat to appreciate. However, this case is inapposite; petitioners did not purchase and hold Brendan or Trinity in order to derive gains from long- term appreciation. There is also nothing on the record from which we can conclude that the value of the yachts would have increased. Petitioners also cite Jackson v. Commissioner, 59 T.C. 312 (1972). In Jackson, we determined that the taxpayer was in the trade or business of renting his yacht. Despite bad weather and damage to the yacht, which forced the taxpayer to cancel most charters, he took other steps to carry on his activity for profit. For example, the taxpayer changed the venue of his activity to the Virgin Islands, where his sailing vessel was in demand. The taxpayer also began a national advertising campaign. In that regard, he engaged a celebrity to advertise his business throughout the nation. We find petitioners' reliance on Jackson to be distinguishable. Here, petitioners did not take alternate steps to carry on their yacht-related activity in a profit- oriented manner. Petitioners' cessation of their activityPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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