George R. and Barbara H. Burrus - Page 39

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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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