- 16 - Petitioner's testimony indicates that his preparation for the apple orchard activity was casual, intermittent, and short- term, rather than extensive. Petitioner did not mention how attending the shows, exhibits, course on pruning trees, or conversations with his neighbor in any way aided petitioners in making the apple orchard activity profitable. Furthermore, there is no evidence in the record that petitioners conducted a thorough investigation into the profitability of their apple orchard activity. They did not present evidence that they had a business plan, or that they had made projections of revenue, expenses, or profits that they expected would be generated by the apple orchard activity. It is unlikely that one would incur such substantial expenses with respect to an activity, which he or she intends to be profitable, without first making a complete investigation of how to do so. Pederson v. Commissioner, T.C. Memo. 1994-555. Accordingly, we find this factor weighs against petitioners. Third, the time and effort expended by the taxpayer in carrying on the activity is an indication of whether a profit motive existed. Sec. 1.183-2(b)(3), Income Tax Regs. Petitioners did expend time on their apple orchard activity as Mrs. Zdun testified that she spent 4 hours each day during the apple season, and petitioner testified that he spent between 500 and 600 hours per year. Although the time that petitioners spentPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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