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operations for the better part of their lives. We are persuaded
that Dr. Burrus’s near lifelong experience with farming,
including livestock, gave him knowledge of both the mechanics and
economics of livestock. In accordance with section 1.183-
2(b)(2), Income Tax Regs., the expertise possessed by Dr. Burrus
and his hired help tends to indicate the existence of a profit
intent.
3. Time and Effort Expended
The fact that the taxpayer devotes much of his or her
personal time and effort to carrying on an activity, particularly
if the activity does not have substantial personal or
recreational aspects, may indicate a profit objective. Sec.
1.183-2(b)(3), Income Tax Regs. The fact that the taxpayer
devotes a limited amount of time to an activity does not
necessarily indicate a lack of profit motive where the taxpayer
employs competent and qualified persons to carry on such
activity. Id.
Dr. Burrus often worked 7 days a week for 10 to 12 hours per
day during the years in issue, and petitioners traveled to Africa
to work at the mission hospital for approximately 2 months of
each year, thereby limiting the amount of time they were able to
personally devote to the cattle activity. Nonetheless, they
hired Mr. Gruen, whose experience and competence have been
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