Dennis L. and Margaret J. Knudsen - Page 31




                                       - 31 -                                         
         most of his energies to the activity may be evidence that the                
         activity was engaged in for profit.  See sec. 1.183-2(b)(3),                 
         Income Tax Regs.                                                             
              Respondent does not dispute that Mrs. Knudsen devoted a                 
         substantial amount of time and effort to petitioners’ exotic                 
         animal breeding activity.  However, respondent argues that Mrs.              
         Knudsen gained personal satisfaction from spending time with the             
         animals, and thus, the significant amount of time and effort she             
         spent with them does not evidence a profit objective.                        
              Although Mrs. Knudsen gained enjoyment from her animals,                
         many of her duties were not personal or recreational.  For                   
         example, Mrs. Knudsen cleaned stalls and cages, disposed of                  
         animal waste and carcasses, and cared for animals during the                 
         night.  The fact that a taxpayer derives some personal                       
         satisfaction from a business does not turn it into a hobby.                  
         Jackson v. Commissioner, 59 T.C. 312, 317 (1972); Giles v.                   
         Commissioner, T.C. Memo. 2006-15; McKeever v. Commissioner, T.C.             
         Memo. 2000-288.                                                              
              Mrs. Knudsen operated and managed ERE.17  Although she worked           
         part time in Dr. Knudsen’s medical practice, Mrs. Knudsen devoted            
         substantial amounts of her time to ERE.  In addition to Mrs.                 
         Knudsen’s labor, ERE hired several employees to help maintain the            

               17During a brief period, ERE hired a manager to help Mrs.              
          Knudsen manage ERE.                                                         







Page:  Previous  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  Next 

Last modified: March 27, 2008