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method in an attempt to improve profitability. Thus, we do not
conclude that these changes indicate a profit motive.
It is clear from the record that petitioners failed to
maintain complete and accurate books and records for the apple
orchard activity, did not conduct the activity in a manner
substantially similar to other comparable, profitable businesses,
and did not make changes in order to improve profitability.
Accordingly, we find this factor weighs against petitioners.
Second, preparation for the start of an activity through
extensive study of its accepted business, economic, and
scientific practices, or consultation with those who are experts
therein indicates that the taxpayer has entered into the activity
for profit. Sec. 1.183-2(b)(2), Income Tax Regs. Petitioner
testified that although he had never raised any type of
commercial farm product before he and Mrs. Zdun purchased the
Tiller property, he had, however, "dabbled" in organic gardening
with his father and another man on 1 or 2 acres in Santa Maria,
California. Petitioner testified that he had attended shows and
exhibits on organic gardening, as well as a course on how to
prune fruit trees. In addition, petitioner consulted with his
neighbor, who has 2,000 trees, about how to grow trees in his
area. Finally, petitioner received advice about planting his
trees from the company in Michigan from which he ordered the
trees.
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