- 33 - Petitioners did not engage Dr. Cortelezzi until 1993, well after the start of their horse activity. As in Daley v. Commissioner, T.C. Memo. 1996-259, petitioners decided to commence their activity with little concept of the expenses involved or of the steps required to achieve cost efficiency and an eventual profit. Petitioners did not prepare for the economic aspects of the activity by study or consultation with experts, and they have not shown that, prior to inception of the activity, they had any concept of what their ultimate costs might be, how they might achieve any degree of cost efficiency, the amount of revenue they could expect, or what risks might impair the production of such revenues. Accordingly, they were unprepared for the economic realities of the horse business. See Rinehart v. Commissioner, T.C. Memo. 1998-205. This factor favors respondent’s position. 3. Petitioners’ Time and Effort The fact that a taxpayer devotes personal time and effort to carry on an activity may indicate an intention to derive a profit, particularly where there are no substantial personal or recreational elements associated with the activity. See Daley v. Commissioner, supra; sec. 1.183-2(b)(3), Income Tax Regs. While working full time, petitioners also managed and operated their paso fino activity during the years at issue.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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