Robert and Joyce Dirkse - Page 15

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          1996, from $79,157 in 1994 to $120,278 in 1996.  In fact,                   
          petitioners acknowledged that they are unable to predict when, or           
          if, their Schedule C activities will become profitable.                     
          Consequently, this factor weighs against a finding of a profit              
               2.  Expertise of Taxpayer or Advisers                                  
               Preparation for an activity after conducting an extensive              
          study or consultation with experts regarding the accepted business          
          practices of the activity may indicate a profit motive where the            
          taxpayer conducts the activity in accordance with such study or             
          advice.  See sec. 1.183-2(b)(2), Income Tax Regs.  Conversely, a            
          taxpayer’s failure to obtain expertise in the activity may indicate         
          a lack of profit motive.  See Burger v. Commissioner, 809 F.2d 355,         
          359 (7th Cir. 1987), affg. T.C. Memo. 1985-523.                             
               Prior to entering into their Schedule C activities,                    
          petitioners consulted with and relied upon the advice of members of         
          the macadamia and persimmon societies, as well as an experienced            
          beekeeper.  Moreover, they spent a considerable amount of time and          
          effort researching their Schedule C activities.  Indeed, when the           
          advice of a paid consultant turned out to be incorrect, petitioners         
          were able to identify the source of the problem and take remedial           
               The fact that petitioners consulted technical, noneconomic             
          experts does not necessarily indicate that they carried on their            

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