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Same way with the orange grove. I was setting
there with the orange grove, paying for my house
anyway, and so it was suggested to me, Why are you
letting the grove go to hell. And so then I started
fixing it up which--probably, very little fruit came
off in the beginning because, like I say, I wasn’t
paying any attention to it. I just thought, well, gee,
nobody makes money off groves, but if you already own
the grove and you can buy a tractor and buy a sprayer
and stuff like this--I always bought used equipment,
and you can see in all the repair things, I had to fix
up old tractors and discs and sprayers and stuff--
[Emphasis added.]
Mr. Partin also testified that, prior to petitioner’s purchase of
the cattle; “He loved the cattle. He’d come--he’d be at my place
off and on, and you know, he just loved the cattle. And we
thought, you know, with his love of the cattle, that’s what it
takes to be in the cattle business.” And, certainly, it is
beyond doubt that the Ferrari automobile has an inherent pleasure
quality, and petitioner has not presented any evidence to suggest
otherwise. Elements of personal pleasure do not alone negate a
profit motivation, see Burger v. Commissioner, supra at 360;
McCarthy v. Commissioner, T.C. Memo. 2000-135; however, on the
record before us we find considerable evidence that the
activities were engaged in for hobby and as a personal diversion.
Petitioner did not maintain any books or records for any of
these purported businesses, and his only method of bookkeeping
with respect to the orange grove and cattle business was his
“checkbook”. The lack of a bookkeeping system such that the
taxpayer could not monitor expenses or losses and could not make
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