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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 activity
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