- 24 - Although petitioner, at the time of his purchase in 1990, may have had an expectation that the Feadship would appreciate in value, the evidence before us establishes that petitioner had no such expectation during 1995, 1996, and 1997. In December of 1994, petitioner listed the Feadship for sale at $2.4 million. As discussed previously, this amount was significantly less than petitioner’s cumulative purchase and restoration costs relating to the Feadship. As stated, petitioner acknowledged that the purpose of chartering the Feadship in 1995, 1996, and 1997 was to offset the costs of operating the Feadship while it was listed for sale. As one of petitioners’ witnesses testified, “if * * * you charter a boat, you can make a couple of bucks * * *.” Time and Effort Expended by Petitioners A profit objective may be indicated by the amount of personal time and effort a taxpayer devotes to carrying on an activity. Sec. 1.183-2(b)(3), Income Tax Regs. Petitioner’s time during the years at issue was largely devoted to his medical practice, allowing petitioner little time to devote to matters relating to the restoration and to the charter of the Feadship. Mrs. Magassy’s efforts relating to the interior design of the Feadship occurred well after the major costs of the restoration on the Feadship had been incurred. Her efforts do not establish an overall profit objective for petitioner or forPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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