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decided to forgo income from haying or pasture rental in an
attempt to reduce the farm’s operating costs and that
petitioner’s attempt to reduce cash losses shows that he had a
profit motive, citing Nickerson v. Commissioner, 700 F.2d 402
(7th Cir. 1983), revg. T.C. Memo. 1981-321. We disagree.
Although he listed the activity as a livestock/hay operation on
his 1995, 1996, and 1997 Schedules E, petitioner produced no hay
or livestock and made no attempt to derive income from hay or
livestock during the years in issue. Further, there is no
evidence that petitioner had a bona fide plan to ever make a
profit from planting and growing trees. This factor favors
respondent.
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 objective.
Sec. 1.183-2(b)(2), Income Tax Regs. A taxpayer’s failure to
obtain expertise in the economics of an activity indicates that
he or she lacks a profit objective. Burger v. Commissioner, 809
F.2d 355, 359 (7th Cir. 1987), affg. T.C. Memo. 1985-523;
Golanty v. Commissioner, 72 T.C. 411, 432 (1979).
Petitioner contends that he had the necessary expertise to
operate a farm because he was born and raised on the Mitchell
farm, he had extensive conversations with other farmers in the
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