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cleaning stalls. He installed the rodeo bleachers and arenas and
cleaned up after the rodeos.
Respondent contends that petitioners could not have been
successful because of their work for Delta. We disagree.
Petitioners relied on Bumgarner when they traveled. The fact
that a taxpayer devotes a limited amount of time to an activity
does not necessarily indicate that he or she lacks a profit
motive if the taxpayer hired and relied on a qualified manager.
Sec. 1.183-2(b)(3), Income Tax Regs. This factor favors
petitioners.
4. Expectation That the Property Used in the Activity
Would Appreciate in Value
Petitioners expected during the years in issue that their
animals would breed and increase in number and value.6 See
Engdahl v. Commissioner, supra at 668-669 (taxpayers expected the
value of their horses to appreciate); Arwood v. Commissioner,
T.C. Memo. 1993-352 (same); Harvey v. Commissioner, T.C. Memo.
1988-13 (same). This factor favors petitioners.
6 We need not decide petitioners' claim that they expected
the value of their farm land to appreciate. Mr. Brockenbrough
testified that he intended to retire on the farm and that he did
not expect the land to appreciate significantly in value when he
bought it.
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