- 29 - Petitioner hired advisers, including geologists and accountants, and sought advice from Government officials regularly. See Jorgenson v. Commissioner, T.C. Memo. 2000-38. For example, petitioner used Mr. Cruson on at least two occasions to advise him on the Tinnell Prospect and the Quartette Mine. In 1999, petitioner hired a geologist to prepare a report detailing the occurrence of uncommon variety materials on petitioner’s claims in the Newberry Mountains in southern Nevada. Petitioner also employed one of his sons at the mine. The evidence demonstrates that L.R. Tinnell has a thorough understanding of both the technical and business aspects of mining. L.R. Tinnell graduated from the University of Nevada, Las Vegas, and also took a graduate-level course in economic geology. L.R. Tinnell was responsible for dealing with Government agencies, such as the U.S. Fish and Wildlife Service, the Nevada Department of Environmental Protection, and the Mine Safety and Health Administration, on behalf of petitioner. L.R. Tinnell was also in charge of underground mining and tests, negotiations with Government agencies, and coordinating assays. This factor favors petitioner. 3. Petitioner’s Time and Effort Devoted to the Activity The fact that a taxpayer devotes personal time and effort to carry on an activity may indicate an intention to derive a profit, particularly where there are no substantial personal orPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011