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wealthy, did not enter farming activity with intent to produce
paper losses to offset nonfarm income). This factor is neutral.
9. Elements of Personal Pleasure
The presence of recreational or personal motives in
conducting an activity may indicate that the taxpayer is not
conducting the activity for profit. Sec. 1.183-2(b)(9), Income
Tax Regs.
Petitioner mended fences, cut underbrush, dug weeds, and
planted trees. Respondent contends that petitioner planted trees
to beautify the farm. Petitioners' residence is located on their
farm, and they have not shown that their farm expenditures did
not benefit their residence and their enjoyment of their
property. See Estate of Dickerson v. Commissioner, T.C. Memo.
1997-165 (Christmas tree farm activity not conducted for profit;
trees provided personal pleasure because they were located near
taxpayers’ residence).
Petitioner enjoyed working on the farm. This fact does not
mean that he did not engage in the activity for profit. The farm
had no recreational facilities, and petitioner worked hard on the
farm. However, it is unclear how much of his work on the farm
had any economic purpose. This factor is neutral.
10. Conclusion
We conclude that petitioner did not operate the farm for
profit in 1995, 1996, and 1997 because he did nothing to generate
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