George R. and Barbara H. Burrus - Page 34

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               As a consequence, any anticipated appreciation in the Maple            
          Row land is not considered in ascertaining the existence of an              
          intent to profit from the cattle activity.  See Roberts v.                  
          Commissioner, T.C. Memo. 1987-404; Hambleton v. Commissioner,               
          T.C. Memo. 1982-234.  With respect to the livestock, we have                
          previously found that petitioners’ purebred herd was growing                
          during the years in issue, and that they were breeding bulls that           
          sold for approximately $2,000 each.  These factors indicate that            
          petitioners had an expectation that the herd would appreciate;              
          under section 1.183-2(b)(4), Income Tax Regs., this expectation             
          tends to indicate the existence of an intent to profit.                     
                    5.  Past Success in Similar or Dissimilar Activities              
               A taxpayer's past success in similar or dissimilar                     
          activities may indicate that his engagement in a presently                  
          unprofitable activity is for profit.  Sec. 1.183-2(b)(5), Income            
          Tax Regs.  Petitioners have enjoyed at least moderate success               
          with MRC, Dr. Burrus has been successful in his medical practice,           
          and the missionary hospital he established in Africa is still               
          operating.  Petitioners’ prior experience with cattle breeding at           
          FBHR was unsuccessful, at least if the appreciation in the value            
          of the Cheatham Property during that period is disregarded.  If             
          the more than doubling in value of the Cheatham Property during             
          the period it was held by the FBHR partnership is taken into                





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