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activity for profit”. Here, petitioner previously started a
computer service business, SRMC, and brought it to the point of
achieving over $2 million in gross income. However, given the
marked differences between petitioner’s history at SRMC and his
ranching venture, general business acumen carries little
probative weight on these facts. Prior to forming SRMC,
petitioner had gained experience with computer systems through
his previous employment at Digital Equipment Corporation. Prior
to purchasing his land, petitioner had virtually no experience
with cattle ranching. In addition, to create a profitable
enterprise through full-time efforts is one thing; to dabble
several days a month is quite another. Moreover, SRMC has now
gone from profitable to unprofitable during petitioner’s tenure.
Based on these differences, an observation by the Court in
Haladay v. Commissioner, T.C. Memo. 1990-45, would seem equally
appropriate here: “The wholesale sporting goods business is
sufficiently dissimilar from farming that even if Raymond’s
Midway business had been a consistently profitable one, a
conclusion that the farming activity should have been equally
profitable would not be warranted.” The admonition by the Court
in Dodge v. Commissioner, T.C. Memo. 1998-89, that the taxpayers
there “did not show that their acquired business expertise was
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