- 22 - of his vacation time to operating Blue Ribbon. Therefore, despite Mr. Abbene's outside employment with Pride Chemicals, we conclude that the time and effort expended by Mr. Abbene is a factor that favors petitioners. 4. Expectation That Assets Used in the Activity May Appreciate in Value An expectation that assets used in the activity may appreciate in value may be an indication of a profit objective. Engdahl v. Commissioner, 72 T.C. 659, 668 (1979); sec. 1.183- 2(b)(4), Income Tax Regs. Respondent argues that petitioners had no expectation of asset appreciation. Petitioners contend that they sincerely and reasonably believed that the property and the horses used in Blue Ribbon's operations would appreciate in value. Petitioners contend that the property had nearly doubled in value since its acquisition in 1975. Although petitioners point to the value of the property, we do not consider it to be relevant to the issue of Mr. Abbene's profit objective with respect to his horse-related activities. While the term "profit" may contemplate appreciation in the value of assets, including land, used in the activity, sec. 1.183-2(b)(4), Income Tax Regs., the holding of land for appreciation will generally be considered a separate activity for purposes of ascertaining a profit motivePage: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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