Terry F. and Carol J. Zdun - Page 15

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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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