Hugh T. Brown, Jr., and Kristi L. Brown - Page 13




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               The nonbusinesslike manner in which petitioner carried on              
          his business would normally weigh against him in the                        
          determination of whether he had a bona fide profit objective.               
          However, as in the Harrison case, because of the speculative                
          nature of petitioner’s business, we view the manner in which he             
          carried on his business as a neutral factor.                                
               2.  The Expertise of Petitioner or His Advisers                        
               Preparation for the activity by extensive study of its                 
          accepted business, economic, and scientific practices or                    
          consultation with people who are expert in these practices may              
          indicate a profit objective where the taxpayer carries on the               
          activity in accordance with such practices.  Sec. 1.183-2(b)(2),            
          Income Tax Regs.                                                            
               Before he started his gold mining activity, petitioner had             
          more than 20 years of work experience in the mining and quarrying           
          industry.  Although petitioner had never mined specifically for             
          gold, he had considerable knowledge of the mining process in                
          general.  In the early 1990s, petitioner began reading                      
          prospecting books and became interested in gold mining.                     
          Petitioner researched the history of abandoned gold mines in                
          California, analyzing their production rates at the time they               
          were abandoned.  Petitioner sought advice from local dealers of             
          gold mining equipment.  He also built his own lightweight                   








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