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losses indicated that the activity was not a hobby).
Petitioners’ financial status does not affect our analysis. See
Callahan v. Commissioner, T.C. Memo. 1996-65, affd. 111 F.3d 892
(5th Cir. 1997). Consequently, 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. See sec. 1.183-2(b)(9),
Income Tax Regs.
Petitioner worked hard planting trees, removing thorns and
brush, and building the pond and access road. We do not know
whether he enjoyed doing that work. Petitioners' residence is
located on their land, and they have not shown that their tree
farm activity 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; the trees provided personal pleasure because they were
located near the taxpayers’ residence). Petitioners have not
shown that they lacked recreational or personal motives for
engaging in the tree activity. This factor is neutral.
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