John R. and Lois J. McCarthy - Page 13




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                  Petitioner did not seek expert advice on how to start or                             
            maintain a business as a fiction writer or as a writer of                                  
            political commentary or about guns.  Petitioner did not consult                            
            with anyone on the economics of conducting a writing activity.                             
            While petitioner had writing skills, they were in the technical                            
            field of engineering and science.  Although his articles about                             
            guns were rather technical, petitioner did not have a background                           
            on gun testing.  Petitioner did not join any literary                                      
            organizations to learn more about the industry.  Petitioner did                            
            attend a writing conference “early on”, but he did not find it                             
            helpful.                                                                                   
                  3. Time and Effort Expended                                                          
                  The fact that the taxpayer devotes much of his or her                                
            personal time and effort to carrying on an activity, particularly                          
            if the activity does not have substantial personal or                                      
            recreational aspects, may indicate a profit objective.  See sec.                           
            1.183-2(b)(3), Income Tax Regs.                                                            
                  We do not question the amount of time petitioner expended in                         
            carrying on the writing activity.  Suffice it to say that he                               
            devoted a great deal of time researching, testing, and writing                             
            about the topics that interested him.                                                      











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