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motive where substantial other income is available, were
insignificant with respect to petitioners’ cattle activity.16 On
balance, we do not believe this factor carries much weight in the
instant case.
9. Personal Pleasure or Recreation
The existence of recreational or personal elements in an
activity may indicate that the activity is not engaged in for
profit. Sec. 1.183-2(b)(9), Income Tax Regs. On the other hand,
where an activity lacks any appeal other than profit, a profit
objective may be indicated. Id. Respondent cites several
examples of recreational activities petitioners undertook on the
Cheatham Property including, inter alia, fishing in the ponds,
horseback riding, the annual dove hunt, and Camp Papa, to argue
that Maple Row’s recreational elements were significant and
should evidence a lack of profit motive. The recreational
elements respondent cites are more appropriately allocable to the
landholding activity than the cattle activity, in our view.
Moreover, petitioners did not maintain a residence at any of the
Maple Row properties, and any personal or recreational aspect of
the apartment available for their use at the Cheatham Property is
likewise allocable to the landholding. While Dr. Burrus had an
16 See discussion of the “recreation” factor, infra.
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