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under the circumstances to demonstrate that the activity was
carried on for profit. Although Mr. Abbene hired an accountant
to maintain Blue Ribbon's books and records, those books and
records may represent nothing more than a conscious attention to
detail. Golanty v. Commissioner, 72 T.C. 411, 430 (1979), affd.
without published opinion 647 F.2d 170 (9th Cir. 1981). In the
instant case there has been no showing that the books and records
were kept for the purpose of cutting expenses, increasing
profits, or evaluating the overall performance of the operation.
Id. Mr. Abbene testified that he reviewed Blue Ribbon's records,
but he has failed to show that he used them to improve the
operation of the enterprise. Id.
Additionally, petitioners concede that, despite mounting
losses, Blue Ribbon was operated in substantially the same manner
from the time it was formed throughout all the years in issue.
We believe that if profit had been the motive, Mr. Abbene would
have either adopted new techniques or abandoned unprofitable
methods in an effort to improve Blue Ribbon's profitability.
Accordingly, we conclude that petitioners failed to establish
that Mr. Abbene operated Blue Ribbon in a businesslike manner.
2. The Expertise of the Taxpayer or the Taxpayer's
Advisers
A taxpayer's expertise, research, and study of an activity,
as well as his consultation with experts may be indicative of a
profit motive. Sec. 1.183-2(b)(2), Income Tax Regs.
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