Dennis L. and Margaret J. Knudsen - Page 41




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              In addition to caring for the animals, petitioners spent a              
         significant amount of time maintaining and improving ERE’s                   
         facilities.  Mrs. Knudsen regularly performed duties that were               
         not pleasurable or recreational, such as cleaning animal cages               
         and stalls and disposing of animal carcasses.  As a result of her            
         duties, she also suffered several physical injuries.  Dr. Knudsen            
         personally did most of the landscaping on the property to provide            
         the animals with a natural habitat.                                          
              The record does not contain evidence that petitioners’                  
         facilities were extravagant or that they were not constructed for            
         the benefit of the animals.  Petitioners maintained their                    
         property in accordance with USDA regulations.  In addition,                  
         petitioners constructed a home on the property, at least in part,            
         to enable them to care for their animals.                                    
              Although petitioners derived some pleasure from their exotic            
         animal breeding activity, we conclude that petitioners were not              
         engaged in the activity solely for personal pleasure or                      
         recreation.                                                                  
              This factor is neutral.                                                 
              C.  Conclusion                                                          
              After considering the factors listed in section 1.183-2(b),             
         Income Tax Regs., all contentions presented by the parties, and              
         the unique facts and circumstances of this case, we conclude that            
         petitioners did not enter the exotic animal breeding activity                







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