- 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 NextLast modified: March 27, 2008