Estate of Edward Brockenbrough, Deceased, Sharon Brockenbrough, and Suntrust Bank, Coexecutors, and Sharon Brockenbrough - Page 29

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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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