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elements of personal pleasure or recreation involved. Sec.
1.183-2(b), Income Tax Regs. No single factor is controlling.
Osteen v. Commissioner, supra at 358; Brannen v. Commissioner,
722 F.2d 695, 704 (11th Cir. 1984), affg. 78 T.C. 471 (1982);
sec. 1.183-2(b), Income Tax Regs. The factors are relevant in
the context of this case to the extent they may indicate whether
petitioner knew or believed that Mr. Rowe was or was not engaged
in the farming activity for profit. See King v. Commissioner,
supra at 205.
Respondent argues that petitioner knew that the farming
activity was not engaged in for profit. Respondent bases his
argument on petitioner’s testimony that the horse activity was a
fun thing for Mr. Rowe to do with his son on the weekends and
that petitioner did not consider the activity an “operation” but
rather her husband just “had a couple of horses in Tampa”.
Respondent contends that petitioner understood that the horse
activity was a fun family recreational activity, and this
understanding establishes that she had actual knowledge that the
horse activity was not engaged in for profit. Additionally,
respondent claims that petitioner had actual knowledge of both
the horse and fish activities, as well as actual knowledge of the
claimed Schedule F losses.
As we noted earlier, petitioner had little or no involvement
in the farming activity. Additionally, she testified that she
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