- 29 - 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.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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