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informed business decisions is persuasive evidence that the
business activity was not engaged in for profit. Burger v.
Commissioner, 809 F.2d at 359. Further, with respect to the
cattle and the orange grove, the record and petitioner’s
testimony show that he had a very primitive expertise in those
activities. For example, even though petitioner noted the
importance of the age of cattle as an “economic factor” in their
“economic production”, he could not testify from personal
knowledge regarding the age of the cattle he acquired from Mr.
Partin. This indicates to us a lack of a bona fide profit
motivation.
Petitioner did not provide evidence of the amount of time
that he devoted to the particular activities during the tax years
at issue, or any evidence that he was required to withdraw from
his real estate business to devote more time to any of those
activities. See McCarthy v. Commissioner, supra; sec. 1.183-
2(b)(3), Income Tax Regs. On the record before us, we find that
petitioner was not engaged in a trade or business with respect to
the orange grove, cattle, and Ferrari activities.
Taxpayers must substantiate any expenses which they claim as
deductions. See Hradesky v. Commissioner, 65 T.C. 87, 89-90
(1975), affd. 540 F.2d 821 (5th Cir. 1976); Tarakci v.
Commissioner, T.C. Memo. 2000-358.71 Further, to be an
71Sec. 274(d) provides for more stringent substantiation
(continued...)
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