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businesslike manner. These facts weigh in favor of respondent.
2. Expertise of Petitioners or Their Advisers
Preparation for the activity by extensive study of its
accepted business, economic, and scientific practices, or
consultation with those who are expert therein, may indicate a
profit motive. Sec. 1.183-2(b)(2), Income Tax Regs.; Engdahl v.
Commissioner, supra at 668; Lundquist v. Commissioner, T.C. Memo.
1999-83, affd. 211 F.3d 600 (11th Cir. 2000). Efforts to gain
experience and a willingness to follow expert advice may indicate
a profit motive. Dworshak v. Commissioner, T.C. Memo. 2004-249;
Lundquist v. Commissioner, supra.
Dr. Remler served as the child neurologist for TEACCH at the
University of North Carolina. Petitioners also received guidance
and training in special education methods from BIA and AIA.
While petitioners had no experience running a school, we find
that Dr. Remler had expertise in dealing with child autism, and
petitioners made efforts to gain experience in special education.
These facts weigh in favor of petitioners.
3. Time and Effort Expended by Petitioners in Carrying
on the Activity
The fact that the taxpayer devotes much of his personal time
and effort to carrying on an activity may indicate an intention
to derive a profit, particularly if the activity does not have
substantial personal or recreational aspects. Sec. 1.183-
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