- 17 - a sign in the window for people to call them if they wanted to see something in the store. This factor favors respondent. 2. The Expertise of the Taxpayers or Their Advisors Preparation for an activity by extensive study of its accepted business, economic, and scientific practices, and consultation with experts in the business, may indicate that the taxpayer entered into the activity for profit. Sec. 1.183- 2(b)(2), Income Tax Regs. Petitioners had no experience operating a retail store. Petitioners spoke to a couple of people about operating an antique store, but, the record contains little detail about the substance of those conversations, and there is no evidence that petitioners sought any advice about how to correct the store's losses in the years in issue. See Engdahl v. Commissioner, supra at 668 (continuous consultation with experts showed profit motive). This factor favors respondent. 3. Taxpayer's Time and Effort The fact that a taxpayer devotes much time and effort to conducting an activity may indicate that the taxpayer has a profit objective. Sec. 1.183-2(b)(3), Income Tax Regs. There is virtually no evidence about how Mrs. Brockenbrough spent her time at the store. Petitioners did not operate the store on a full- time basis after 1990. This factor favors respondent.Page: 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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