Dean L. and Cynthia D. Sanders - Page 21





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               We find that petitioner did not carry on the activity in a             
          businesslike manner.                                                        
                    5.  Expertise of Taxpayer or His Advisors                         
               “Preparation for the activity by extensive study of its                
          accepted business, economic, and scientific practices, or                   
          consultation with those who are expert therein, may indicate that           
          the taxpayer has a profit motive where the taxpayer carries on              
          the activity in accordance with such practices.”  Sec. 1.183-               
          2(b)(2), Income Tax Regs.  While petitioner received free and               
          paid advice from individuals he considered "experts" in the                 
          cutting horse industry, the advice did not focus on the economic            
          aspects of the activity.  The advice which petitioner received on           
          profitable bloodlines and which horses to sell is consistent with           
          a hobbyist's motives.  Taken as a whole, we find this factor to             
          be neutral.                                                                 
                    6.  Time and Effort                                               
               "The fact that the taxpayer devotes much of his personal               
          time and effort to carrying on an activity, particularly if the             
          activity does not have substantial personal or recreational                 
          aspects, may indicate an intention to derive a profit.”  Sec.               
          1.183-2(b)(3), Income Tax Regs.  During 1992 and 1993, petitioner           
          spent 15 to 18 hours a week in connection with the Schedule F               
          activity.  He employed a professional trainer, but he testified             
          that he also helped with training.  Petitioner managed the                  





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