Roderick P. Strickland and Linda G. Strickland - Page 18




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          broodmares.  They tried to keep costs as low as possible.  This             
          factor favors petitioners.                                                  
               2.   The Expertise of the Taxpayers or Their Advisers                  
               Efforts to gain experience, a willingness to follow expert             
          advice, and preparation for an activity by extensive study of its           
          practices may indicate that a taxpayer has a profit motive.  See            
          sec. 1.183-2(b)(2), Income Tax Regs.                                        
               Respondent contends that petitioners did not seek or have              
          the economic expertise necessary to operate the horse activity              
          profitably.  Respondent points out that petitioners did not show            
          a profit from 1993 to 1996, and that none of the material that              
          petitioners reviewed or experts with whom they talked addressed             
          how to make a profit or minimize losses.  Petitioner knew a lot             
          about breeding, raising, training, boarding, buying, and selling            
          of horses and the costs associated with those actions.  Mr.                 
          Strickland had extensive business experience.  Petitioners read             
          books and periodicals, viewed videotapes, attended seminars, and            
          consulted with experts.  We believe that petitioners had the                
          expertise to conduct a profitable horse activity.  This factor              
          favors petitioners.                                                         
               3.   Taxpayer's Time and Effort                                        
               The fact that a taxpayer devotes much time and effort to               
          conducting an activity may indicate that he or she has a profit             
          objective.  See sec. 1.183-2(b)(3), Income Tax Regs.                        






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