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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.
Petitioner grew up on his parents’ cattle ranch; he learned
firsthand the basics of raising and breeding cattle. He spent
considerable time consulting with the USDA Soil Conservation
Service, as well as State game and wildlife agencies. In addition,
he is an experienced deer hunter. Consequently, he possessed a
substantial level of expertise regarding cattle and deer.
However, the fact that petitioner had knowledge of cattle and
deer, and that technical noneconomic experts were consulted, does
not indicate that petitioners engaged in their cattle-raising and
deer operations for profit. See Hillman v. Commissioner, supra.
Considering all the years of losses, petitioners did little to
demonstrate an expertise for the economics of these operations.
3. Time and Effort Expended in the Activity
The fact that a taxpayer devotes much of his or her personal
time and effort in carrying on an activity, particularly if the
activity does not have substantial recreational aspects, may
indicate a profit motive. See sec. 1.183-2(b)(3), Income Tax Regs.
Petitioner spent approximately 40 percent of each year on both
ranches; Mrs. Kahla spent approximately 10 percent. The record
does not indicate the proportion of time spent on each ranch during
the years in issue or the amount of personal effort each expended
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